Minnesota Reinforces Employer Duty to Engage in the Interactive Process - HR ALERTS

Minnesota Reinforces Employer Duty to Engage in the Interactive Process

Effective Date:  August 1, 2026

Minnesota has amended the Minnesota Human Rights Act to clarify that an employer's failure to engage in the interactive process to determine whether a reasonable accommodation can be provided may constitute an unfair discriminatory practice.

Why This Matters

The interactive process is a collaborative discussion between an employer and an employee or applicant to identify a reasonable accommodation that enables the individual to perform the essential functions of the job. Employers should not deny an accommodation request without first engaging in this good-faith dialogue.

Recommended Next Steps

• Review reasonable accommodation policies and procedures.

• Train managers and HR personnel on the interactive process.

• Document accommodation discussions and decisions.

• Consult HR or legal counsel before denying an accommodation request.

Reference:  Minnesota S.B. 3210  

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