As return-to-office mandates rise, so, too, do employee requests for telework accommodations under the Americans with Disabilities Act (ADA). On Feb. 11, 2026, the U.S. Equal Employment Opportunity Commission (EEOC) released guidance titled “Frequently Asked Questions from the Federal Sector about Telework Accommodations for Disabilities” (FAQs), which address federal government agencies’ rights and obligations regarding providing, modifying, and denying telework as a reasonable accommodation for federal employees with disabilities under the federal Rehabilitation Act of 1973. Although the EEOC issued the guidance in the federal-sector context in the wake of President Donald Trump’s directive that federal agencies return employees to full-time, in-person work, the FAQs reflect principles that apply equally to private employers under the ADA.

The FAQs cover a wide range of topics related to telework as a reasonable accommodation for employees with mental and physical disabilities. They offer an illuminating roadmap of the EEOC’s position on a number of complicated issues that employers face. Below is a summary of some of the more significant points.

Employers should recognize when telework qualifies as a reasonable accommodation — and when it does not.

Under the ADA, reasonable accommodations, including telework, must enable an individual to accomplish one of the following: (1) participation in the application process, (2) performance of essential functions, or (3) access...

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