Updated Guidance on Religious Objections to Employer COVID-19 Vaccine Mandates

October 27, 2021

As the world continues to deal with the effects of the COVID-19 pandemic, many employers have begun to require employees to be vaccinated against COVID-19 as a condition of their employment. This has undoubtedly raised many questions an employer’s ability to mandate that their employees get vaccinated. On October 25, 2021, the U.S. Equal Employment Opportunity Commission (EEOC) released updated guidance to address questions about Title VII and religious objections to employer COVID-19 vaccine mandates.


Title VII of the Civil Rights Act protects an employee from discrimination based on race, color, religion, sex, and national origin. Likewise, Title VII requires employers to accommodate employees’ “sincerely held religious beliefs, practices, or observances absent undue hardship.” This includes the requirement that employers consider requests of employees who seek to be exempt from a COVID-19 vaccination requirement based on a sincerely held religious belief.


Employees who wish to be exempt from a vaccine mandate due to a sincerely held religious belief must inform their employer of this. Employers must then demonstrate that “undue hardship” is not required to accommodate the request. It is important to note that Title VII does not require employers to consider requests for exemption based on social, political, or economic views, or personal preference of the employee. The ability to grant or deny a requested exemption rests heavily on the elements of “undue hardship” and a showing of a sincerely held religious belief.


If you have any questions about the elements of the undue hardship requirement, religious and other Title VII exemptions to employer COVID-19 vaccination mandates, or other employment issues generally, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.

By The Royal Law Firm August 15, 2025
Royal attorneys successfully obtained a Partial Dismissal on a USDC MA case. The Plaintiff alleged discrimination on the basis of sex, pregnancy, parental leave, and retaliation. The court agreed with our arguments and dismissed the 93A claims.
July 25, 2025
On June 27, 2025, the U.S. Supreme Court ruled in Trump v. CASA that federal district courts cannot block executive orders for the entire country. The Court held that such broad injunctions exceed the authority Congress granted under the Judiciary Act of 1789. Courts may now only stop enforcement for the parties in the case—not for everyone else. What Happened in the Case President Trump issued Executive Order 14160 in early 2025. It denies birthright citizenship to children born in the U.S. if neither parent is a citizen or lawful permanent resident. Multiple lawsuits followed. Three federal courts blocked the order nationwide. The Supreme Court disagreed. It sent the case back and told the lower courts to revise the injunctions to cover only the named plaintiffs. The Court did not decide whether the order itself violates the Constitution. It ruled only on how far a court’s injunction can reach. Why It Matters to Employers The ruling affects how quickly and widely federal courts can stop controversial policies, especially during fast-changing political cycles. Employers have often relied on national injunctions to pause new mandates on wages, workplace safety, pay transparency, and non-compete agreements. This decision limits that option. The Court said nothing about injunctions under the Administrative Procedure Act, which governs agency rules. But the opinion raises doubts about whether even those can continue on a nationwide scale. Justice Kavanaugh suggested they might, but the Court left that question for another day. What This Means for You No nationwide protection unless you sue If your business is not part of the case, you likely cannot rely on someone else’s win. You must litigate directly to get relief. Rules may take effect in one state and not another A federal court in Texas may block a rule, while a court in New York upholds it. National companies may face conflicting rules and inconsistent enforcement. Trade groups cannot shield you Even if your industry association wins an injunction, it may apply only to their members or to the parties named in the lawsuit. Older rulings may now shrink Past national injunctions—on vaccine mandates, non-compete bans, overtime rules, or joint-employer standards—could be challenged or narrowed based on this ruling. More class actions are likely Some plaintiffs may now push for class certification to restore broader relief. Employers could face more complex litigation as a result. Next Steps for Employers Identify any current or past rules your business has relied on that are being blocked nationwide. Confirm whether you were covered by name or just assumed you were protected. Reassess your risk exposure for pending federal actions under OSHA, the EEOC, the DOL, or the NLRB. Monitor APA-based injunctions to see whether courts continue to grant broad relief under that statute. Consider joining strategic litigation early if new executive orders or agency rules would harm your operations. You cannot assume another company’s lawsuit will protect you. The Court narrowed that path. To block a federal mandate, you may now need to act alone—or join the fight directly. Michael P. Lewis is an attorney at The Royal Law Firm with experience advising clients through the litigation process. Michael helps employers resolve workplace challenges with focus, precision, and judgment. He counsels and defends businesses across Massachusetts and Connecticut, handling matters involving discrimination, harassment, retaliation, wage and hour claims, restrictive covenants, and breach of contract. His practice includes litigation in state and federal courts and before administrative agencies. If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.