Reasonable accommodation for disabled workers, by country
Four of these laws state an adjustment duty in terms of disability and limit it by cost or hardship, but the limits are worded differently: the United States asks for significant difficulty or expense, Canada weighs health, safety and cost, Norway asks whether the burden is disproportionate, and Sweden asks what is reasonable. France is the outlier. Its duty applies only to an employee declared unfit by the occupational physician after illness or injury, and ends in a reassignment offer rather than an adjustment of the existing job.
Scope of this guide
Canada: the Canada Labour Code (federal sector) and the Ontario statutes that LawAsked has loaded. Other provinces are not compared.
United States: federal law only. State law is not compared.
| Country | Employer duty | Who is covered | Limit on the duty |
|---|---|---|---|
| Canada | To rely on a job requirement, the employer must show the person's needs cannot be accommodated | Individuals affected by a practice in employment, on a prohibited ground including disability | Undue hardship, considering health, safety and cost |
| France | Offer another suitable job, adapted if needed (adjusted posts or working time), comparable to the previous one | Employee declared unfit by the occupational physician after illness or injury | Employer may dismiss if it shows it cannot offer a job, the employee refuses, or the physician states no reassignment is possible |
| Norway | Suitable individual accommodation of the hiring process, workplace and tasks | Job applicants and employees with a disability | Accommodation that does not impose a disproportionate burden: effect, cost and the employer's resources |
| Sweden | Take reasonable accessibility measures so the person is in a comparable situation to people without the disability | Employees, trainees, hired-in staff and job applicants (not those who only ask about work) | Measures that are reasonable given economic and practical conditions, length of the relationship and other circumstances |
| United States | Make reasonable accommodations to known limitations of a qualified individual | Applicants and employees with a disability who are otherwise qualified | Undue hardship: significant difficulty or expense |
Country by country
Canada
- Rule
- Canadian Human Rights Act s 15(1)(a) and (2)
- Federally regulated employers only. The duty is written as a condition of the bona fide occupational requirement defence: the employer must establish that accommodating the individual or class affected would impose undue hardship.
- The Governor in Council may make regulations setting standards for assessing undue hardship.
- Ontario human rights law is not ingested.
it must be established that accommodation of the needs of an individual or a class of individuals affected would impose undue hardship on the person who would have to accommodate those needs, considering health, safety and costThe Governor in Council may make regulations prescribing standards for assessing undue hardship. disability means any previous or existing mental or physical disability France
- Rule
- Code du travail arts. L1226-2, L1226-2-1 and L1226-10
- This is not a general disability accommodation duty. It applies after a declaration of unfitness for the previous job, whether the illness or accident is work-related (L1226-10) or not (L1226-2).
- The offer must take account of the physician's written conclusions and the opinion of the works council where there is one. An employer who cannot offer a job must give the reasons in writing.
est déclaré inapte par le médecin du travaill'employeur lui propose un autre emploi approprié à ses capacitésau besoin par la mise en oeuvre de mesures telles que mutations, aménagements, adaptations ou transformations de postes existants ou aménagement du temps de travail Lorsqu'il est impossible à l'employeur de proposer un autre emploi au salarié, il lui fait connaître par écrit les motifs qui s'opposent à son reclassement.soit du refus par le salarié de l'emploi proposé dans ces conditions Lorsque le salarié victime d'un accident du travail ou d'une maladie professionnelle est déclaré inapte par le médecin du travail Norway
- Rule
- Likestillings- og diskrimineringsloven §§ 12 and 22
- Applies to applicants and employees. Breach of the accommodation duty counts as discrimination.
- The right covers getting or keeping work, access to training and development, and doing and advancing in the work on an equal footing with others.
Arbeidstakere og arbeidssøkere med funksjonsnedsettelse har rett til egnet individuell tilrettelegging av ansettelsesprosess, arbeidsplass og arbeidsoppgaverRetten gjelder tilrettelegging som ikke innebærer en uforholdsmessig byrde.tilretteleggingens effekt for å fjerne barrierer for personer med funksjonsnedsettelsevirksomhetens ressurser regnes som diskriminering Sweden
- Rule
- Diskrimineringslag 1 kap. 4 § and 2 kap. 1 §
- An employer may not discriminate against those listed, and failing to provide accessibility measures (bristande tillgänglighet) is defined as discrimination.
- The ban on this form of discrimination does not apply to a person who only makes an inquiry about work.
bristande tillgänglighet: att en person med en funktionsnedsättning missgynnas genom att sådana åtgärder för tillgänglighet inte har vidtagitsde ekonomiska och praktiska förutsättningarnavaraktigheten och omfattningen av förhållandet eller kontakten mellan verksamhetsutövaren och den enskilde En arbetsgivare får inte diskriminera den som hos arbetsgivarenFörbudet mot diskriminering i form av bristande tillgänglighet gäller inte i fråga om den som gör en förfrågan om arbete. United States
- Rule
- Americans with Disabilities Act, 42 U.S.C. §§ 12111 and 12112(b)(5)
- Federal law only. The duty applies to a known physical or mental limitation, and the employer must be able to show undue hardship to refuse.
- Accommodations the Act lists include making facilities accessible, job restructuring, part-time or modified schedules, reassignment to a vacant position and acquiring or modifying equipment.
- Hardship is judged on cost, the resources of the facility and of the whole business, its size and the type of operation.
not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless such covered entity can demonstrate that the accommodation would impose an undue hardship on the operation of the business of such covered entity making existing facilities used by employees readily accessible to and usable by individuals with disabilitiesjob restructuring, part-time or modified work schedules, reassignment to a vacant positionan action requiring significant difficulty or expensethe overall financial resources of the covered entity Countries not in this table yet
Germany, Austria, Spain, the Netherlands, Australia and Japan are not shown. The ingested German and Austrian equal-treatment acts, the Spanish Estatuto de los Trabajadores, Dutch Civil Code Book 7, the Australian Fair Work Act and the Japanese labour statutes state no employer duty of reasonable accommodation, and the disability laws that would (such as the German Social Code IX or the Japanese disabled-employment law) are not ingested. The United Kingdom is not shown because the Equality Act 2010 is not ingested.
How this table was built
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Each figure is tied to a passage quoted word for word from that text. When the page is served, it checks that every quoted passage is still in the current text of a law that is in force; if a law is amended and its wording changes, that row is hidden until a person reviews it again.
The table shows the statutory minimum only. Collective agreements, awards and individual contracts often give more than the statute, and some countries let a collective agreement set different terms.
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LawAsked, “Reasonable accommodation for disabled workers, by country”, https://lawasked.com/guides/disability-reasonable-accommodation (reviewed October 25, 2026).
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