Navigating pregnancy accommodations in the workplace: Essential 2025 rules

Pregnancy shouldn’t mean putting your career on pause. Yet for many women, the physical demands of pregnancy can create workplace challenges that impact their ability to perform job duties. With recent legislative changes, both employers and employees need to understand the evolving landscape of pregnancy accommodations.

The Pregnant Workers Fairness Act: A game-changer for workplace rights

The Pregnant Workers Fairness Act (PWFA) marked a significant shift in workplace protections when it went into effect on June 27, 2023, with the EEOC’s Final Rule implementation following on June 18, 2024. This groundbreaking legislation provides pregnant workers with rights similar to those provided by the Americans with Disabilities Act, requiring employers to offer reasonable accommodations for pregnancy-related conditions unless doing so would cause undue hardship.

The PWFA applies to employers with 15 or more employees, covering both public and private workplaces across the United States. It works alongside existing protections from Title VII, the Pregnancy Discrimination Act, and the Family and Medical Leave Act to create a more comprehensive safety net for pregnant workers.

As noted in the EEOC’s implementation guidelines, these protections extend beyond just pregnancy itself to include a wide range of “related medical conditions.”

What counts as a “pregnancy-related condition”?

Under the PWFA, the scope of protected conditions is deliberately broad. The law recognizes that pregnancy impacts women’s bodies in diverse ways, with conditions that may require workplace accommodations including morning sickness, gestational diabetes, pregnancy-induced hypertension, pregnancy-related carpal tunnel syndrome, and sciatica. The protections don’t end with pregnancy itself – they extend to lactation needs, recovery from childbirth, recovery from pregnancy loss (including miscarriage, stillbirth, and abortion), and postpartum depression.

According to the National Women’s Law Center, this comprehensive definition ensures that women receive support throughout their reproductive health journey, not just during active pregnancy. This broad protection acknowledges the complex physical and emotional impacts that can accompany the reproductive process.

Understanding “reasonable accommodations”

The cornerstone of the PWFA is the requirement for “reasonable accommodations” – modifications or adjustments that allow pregnant employees to perform essential job functions. These accommodations should address “known limitations” related to pregnancy or childbirth.

Reasonable accommodations typically fall into several categories. Schedule flexibility accommodations might include additional or longer breaks for rest, hydration, or bathroom use; modified work schedules to accommodate morning sickness or medical appointments; or temporary remote work options for high-risk pregnancies. Physical modifications could involve seating options for jobs that typically require standing, lifting restrictions or assistance with heavy items, temporary reassignment of physically demanding tasks, or ergonomic adjustments to workstations. Environmental adjustments might include temperature controls for employees experiencing pregnancy-related heat sensitivity, private and clean spaces for lactation breaks, closer parking spaces to reduce walking distances, or uniforms and dress code modifications.

While these accommodations benefit pregnant employees, they often require minimal cost or disruption for employers. According to the National Partnership for Women & Families, employers cannot deny employment opportunities based on the need for these reasonable accommodations, nor can they retaliate against employees who request them.

The interactive process: How to request accommodations

When a pregnant employee needs workplace adjustments, both parties should engage in an “interactive process” – a collaborative discussion to determine appropriate accommodations. This process begins when an employee initiates the request, informing their employer about pregnancy-related limitations requiring accommodation. While not required to use specific language, being clear about the need for adjustments due to pregnancy is helpful.

Documentation considerations come into play when the need isn’t obvious. Employers may request reasonable documentation, but as clarified in EEOC guidelines, documentation requests must be limited to determining if the employee has a physical or mental condition related to pregnancy.

The heart of the process involves collaborative solution-finding where both parties discuss potential accommodations that would address the limitation without causing undue hardship for the business. Once an accommodation is agreed upon, it should be implemented promptly, with the understanding that the solution may need adjustment as pregnancy progresses or conditions change.

Understanding these pregnancy accommodation rights is crucial for expecting mothers. Our Pregnancy Course at Beginning Academy provides comprehensive education on managing pregnancy in professional settings, including detailed guidance on understanding and exercising workplace rights.

Regulatory uncertainty in 2025

The implementation of the PWFA faces challenges in 2025 due to ongoing litigation and potential policy shifts. According to a recent federal court ruling, 17 state attorneys general have filed challenges against the EEOC’s Final Rule, with the U.S. Court of Appeals for the Eighth Circuit determining states have standing to challenge the regulations.

Additionally, EEOC leadership changes have created uncertainty about enforcement priorities. Acting EEOC Chair Lucas has indicated support for “minor, simple, temporary accommodations” while suggesting the commission may reconsider portions of the Final Rule that could be “unsupported by the law” once a quorum is re-established, as detailed in a Bradley University analysis.

The geographical application of the law has also become uneven. A U.S. District Court for the Western District of Louisiana postponed abortion accommodation requirements for Louisiana and Mississippi on June 17, 2024, creating a patchwork of enforcement that employers with multi-state operations must carefully navigate. This evolving landscape means both employers and employees should stay informed about the latest developments in PWFA implementation and enforcement.

When accommodations become an “undue hardship”

Employers may deny accommodation requests if they would cause “undue hardship” – significant difficulty or expense considering the employer’s size, financial resources, and operational structure. However, this exception has a high threshold, particularly for low-cost accommodations like schedule adjustments or temporary duty modifications.

According to Mintz legal analysis, employers must engage in the interactive process in good faith before claiming undue hardship, documenting specific business reasons why accommodations cannot be provided. This requires a case-by-case assessment rather than blanket policies rejecting certain types of accommodations.

The burden falls on employers to demonstrate that an accommodation would significantly disrupt operations or impose substantial costs disproportionate to the company’s resources. For most businesses, especially larger organizations, proving undue hardship for common pregnancy accommodations can be difficult, as many adjustments require minimal investment while yielding benefits in employee retention and productivity.

Real-world accommodation examples

Understanding how these accommodations work in practice can help both employers and employees navigate the process more effectively. Consider a retail sales associate experiencing severe morning sickness who requested a later start time and more frequent breaks. Her employer adjusted her schedule to begin at 10 AM instead of 8 AM and provided a private area for brief rest periods, allowing her to maintain productivity while managing symptoms.

In another case, an office worker with gestational diabetes required strict meal timing and blood sugar monitoring. Her employer provided scheduled breaks for snacks and testing, placed her workstation near the break room, and allowed her to keep necessary supplies at her desk, accommodations that enabled her to manage her condition while continuing to perform her role effectively.

A warehouse team member received medical advice to avoid lifting over 20 pounds. Rather than taking leave, her employer temporarily reassigned her to inventory management and quality control duties that didn’t require heavy lifting, maintaining her hours and pay rate while ensuring workplace safety.

For a high school teacher experiencing late-pregnancy pelvic pain, accommodations included a stool to sit while teaching, reduced hallway monitoring duties, and a classroom location closer to restrooms. These adjustments allowed her to continue teaching until her planned maternity leave, maintaining continuity for her students while protecting her health.

Best practices for employers in 2025

Despite regulatory uncertainty, employers can implement best practices to support pregnant employees while ensuring compliance. Developing clear accommodation procedures creates straightforward processes for requesting and evaluating pregnancy accommodations, reducing confusion and inconsistency. Training managers appropriately ensures supervisors understand PWFA requirements and handle accommodation requests properly, minimizing legal risk.

Documenting the interactive process helps maintain records of accommodation discussions, decisions, and implementations, creating valuable evidence of good-faith compliance efforts. Considering temporary job modifications explores creative solutions like duty shuffling within teams rather than requiring leave, often benefiting overall workflow and team dynamics.

Reviewing policies regularly allows organizations to update accommodation procedures as regulatory guidance evolves throughout 2025. When facing complex accommodation requests or potential undue hardship situations, consulting legal counsel provides tailored guidance that accounts for the organization’s specific circumstances and the latest legal developments.

Taking control of your pregnancy journey at work

Understanding your rights under the PWFA empowers you to advocate for the accommodations you need during pregnancy. By initiating early conversations with employers and clearly communicating your needs, you can create a supportive work environment that allows you to maintain your career while protecting your health.

For personalized support through your pregnancy journey, Beginning.com offers comprehensive resources to help you navigate both physical and professional challenges. Our Pregnancy Course provides evidence-based guidance on managing pregnancy symptoms, understanding workplace rights, and maintaining overall wellbeing during this transformative time.

Remember that pregnancy accommodations aren’t special treatment—they’re essential adjustments that allow you to continue contributing your talents and skills while nurturing new life. By understanding and advocating for these rights, you help create more supportive workplaces for all women.