In July 2025, the U.S. Office of Personnel Management (OPM) issued two important memos regarding religious accommodations and religious expression in federal workplaces. Although these memos apply only to federal agencies, they increase the likelihood that the U.S. Equal Employment Opportunity Commission (EEOC) will adopt similar guidance for private employers in the future.

Quick Hits

• In mid-July 2025, OPM issued a memo that emphasizes federal agencies’ obligations to provide religious accommodation and identifies types of religious accommodations agencies should consider.
• Two weeks later, OPM issued a memo that expands religious expression in federal workplaces.
• The OPM memos align with recent executive orders and guidance from the Trump Administration related to religious freedoms, as well as EEOC enforcement priorities, and may foreshadow further guidance and directives applicable to private sector workplaces.

The First Amendment of the U.S. Constitution prohibits the government from establishing a state religion or favoring one religion over others. In addition, Title VII of the Civil Rights Act of 1964 bans employment discrimination based on religion and other protected characteristics. Federal agencies and private employers long have been required to engage in a good-faith interactive process with employees to explore reasonable accommodations for sincerely held religious beliefs and provide such accommodations unless they impose an undue hardship. Prior to...

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