EEOC guidance clarifies ADA accommodation rules after Walmart settlement

The Equal Employment Opportunity Commission issued enforcement guidance that lays out clear, practical obligations for employers and employees under the Americans with Disabilities Act, offering specifics on how reasonable accommodations should be requested, evaluated, and provided. The guidance is especially relevant to Walmart associates and managers in light of a Jan. 12, 2026 EEOC settlement involving the company.

The guidance stresses that employees or applicants need not use legal terms when asking for an accommodation; a plain-language request is sufficient. Requests can be made orally or in writing, and employers are expected to begin an interactive process promptly. When a disability or need is not obvious, the employer may request reasonable medical documentation to establish the condition and the limitations that give rise to the accommodation request.

The EEOC guidance highlights six practical points managers and HR teams should heed. Employers can choose among effective accommodations and are not required to supply the exact accommodation an associate requests if an alternative will work. Accommodations should be provided promptly, though what counts as promptness depends on the circumstances. Employers should avoid policies that force employees to submit repeated paperwork for recurring accommodations, a practice the guidance identifies as problematic. The guidance also covers the undue hardship standard, reiterating that employers may deny accommodations that would impose undue hardship on operations.

For Walmart associates, the guidance has immediate implications for common workplace issues: schedule adjustments for medical appointments or chronic conditions, temporary restrictions on lifting or stocking, modified duties on the sales floor, and adjustments to attendance procedures. Store and club managers, People Services representatives, and HR partners will need to be ready to accept plain-language requests, document the interactive process, and evaluate alternatives rather than defaulting to rigid checkbox procedures.

Operationally, this means training line managers to recognize accommodation requests, starting timely conversations with associates, and working with regional HR to assess documentation needs without imposing unnecessary burdens. Avoiding a requirement for repeated medical forms for a known, recurring condition can reduce friction and lower the risk of administrative errors that escalate into complaints or enforcement actions.

The EEOC guidance provides a practical roadmap for handling accommodations, and the Jan. 12 settlement underscores the enforcement context in which these rules apply. For associates, the takeaway is straightforward: state your need in plain language and expect an interactive response. For managers and HR, the guidance calls for timely, flexible responses and a review of policies that may inadvertently create barriers to accommodation.