TL;DR: What You Need to Know About Pregnancy Accommodation Compliance in 2025
New federal and state laws have redefined what employers must do to stay compliant with pregnancy accommodation rules in 2025. The Pregnant Workers Fairness Act (PWFA) now requires employers to provide reasonable accommodations for any pregnancy-related limitations—not just those that qualify as disabilities. In New York, a new law effective January 1, 2025 mandates 20 hours of paid prenatal care leave, tracked separately from sick time.
Why it matters:
Professional service firms are especially vulnerable due to informal processes, minimal HR infrastructure, and outdated handbooks. A single misstep—like denying a flexible schedule or misclassifying prenatal leave—can trigger costly lawsuits or audits.
Key takeaways:
- Update your policies to reflect the PWFA and NY prenatal leave law
- Train managers to recognize and properly respond to accommodation requests
- Avoid bundling prenatal leave with other paid leave
- Document every request and your interactive process
Bottom line: Compliance in 2025 requires more than good intentions—it demands proactive systems, clear communication, and up-to-date policies.
Introduction: Why This Matters More Than Ever
In 2025, pregnancy accommodation compliance isn’t just a legal checkbox—it’s a moving target with sharp edges. For professional service firms juggling tight deadlines, lean HR teams, and evolving work models, the changes in federal and state laws around pregnancy-related rights are not only easy to miss—they’re easy to mishandle.
The Pregnant Workers Fairness Act (PWFA), now under full enforcement, has redefined how accommodations must be approached. At the same time, states like New York are layering on additional obligations, such as mandatory paid prenatal care leave, which took effect on January 1, 2025. These new rules don’t just expand entitlements—they expose operational blind spots that many firms never knew existed.
What makes pregnancy accommodation compliance in 2025 so complex isn’t the paperwork. It’s the human element: informal policies, misinformed managers, and assumptions that can turn routine requests into six-figure liabilities. The firms that will thrive aren’t the ones who wait for a complaint—they’re the ones who build compliance into culture before a lawsuit forces their hand.
The 2025 Legal Landscape: What’s Changed in Pregnancy Accommodation Law?
Pregnancy accommodation compliance in 2025 demands more than basic awareness of the law—it requires a nuanced understanding of how multiple legal frameworks now interact. The days of relying solely on the Americans with Disabilities Act (ADA) or the Family and Medical Leave Act (FMLA) to handle pregnancy-related issues are over.
The Pregnant Workers Fairness Act (PWFA) is now in full effect and being actively enforced by the Equal Employment Opportunity Commission (EEOC). Unlike the ADA, which only applies to pregnancy-related conditions that rise to the level of a disability, the PWFA requires covered employers to accommodate any known limitations related to pregnancy, childbirth, or related medical conditions—even when those limitations wouldn’t otherwise qualify under the ADA. This subtle but significant shift redefines the employer’s obligation to engage in the interactive process without waiting for a formal request.
Layered on top of that is New York’s new Prenatal Care Leave law, effective January 1, 2025. Employers must now offer up to 20 hours of paid leave annually for prenatal medical visits. This leave must be tracked separately from other forms of leave like sick days or Paid Family Leave. Failing to distinguish between these entitlements can trigger compliance violations across multiple statutes.
For detailed guidance, the EEOC’s official resource on the PWFA outlines what employers must do to stay compliant.
The 2025 reality? Pregnancy-related compliance now requires multi-layered systems, updated policies, and more efficient internal workflows to keep pace with evolving laws and increasing enforcement.
Why Professional Service Firms Are at Higher Risk in 2025
Pregnancy accommodation compliance in 2025 poses unique risks for professional service firms—especially those that operate with flat structures, minimal HR staffing, and a culture that values informal communication over documented protocols. While these environments often foster agility and efficiency, they can also create blind spots when it comes to employment law obligations.
In firms where managers double as HR or where policies haven’t been updated in years, the risk of noncompliance is amplified. Unlike larger organizations with dedicated compliance teams, professional service firms often lack the infrastructure to monitor overlapping legal obligations at the federal, state, and local levels. This is particularly problematic in jurisdictions like New York and New Jersey, where additional laws like the NY Prenatal Care Leave and New Jersey Law Against Discrimination (NJLAD) create stricter standards than federal law alone.
One of the most overlooked vulnerabilities? Manager discretion. In many firms, supervisors informally handle requests for accommodations—whether it’s modified schedules or remote work—without realizing these decisions may carry legal weight. A manager’s “no” in a casual conversation can easily be cited as evidence of discrimination or failure to accommodate.
Moreover, compliance risk is no longer confined to the courtroom. Regulatory scrutiny is increasing, and employees are increasingly aware of their rights. Firms may also face reputational damage online if an accommodation is mishandled, particularly on employer review sites like Glassdoor.
The bottom line: in 2025, professional service firms that fail to implement a formal, proactive approach to pregnancy accommodation compliance face both legal and brand-related consequences that go far beyond outdated policies.
What Counts as a Pregnancy Accommodation in 2025?
Pregnancy accommodation compliance in 2025 now goes far beyond traditional assumptions. It’s not just about offering a stool or reducing heavy lifting. The definition of a reasonable accommodation under the Pregnant Workers Fairness Act (PWFA) and state law in New Jersey and New York, includes a wide range of workplace adjustments—many of which are frequently overlooked.
Accommodations can include additional breaks to manage nausea or fatigue, flexible scheduling for prenatal appointments, remote work for high-risk pregnancies, or time off to recover from childbirth-related complications. Even accommodations for mental health conditions related to pregnancy—such as perinatal anxiety or depression—fall squarely within the PWFA’s scope. These are not fringe cases; they are increasingly common and legally protected.
In New York, employers must also now provide up to 20 hours of paid leave per year for prenatal medical appointments under Labor Law § 196-b. This new leave must be treated as a separate entitlement from sick leave or Paid Family Leave. Misclassifying or deducting this time from other banks may lead to dual violations under state and federal law.
Another area often missed: accommodations related to miscarriage or loss of pregnancy. Under the EEOC’s final regulations, employers are explicitly required to treat pregnancy loss as a condition eligible for reasonable accommodation, whether it results in physical recovery time or emotional distress.
A useful summary of employer obligations under the PWFA can be found in the EEOC’s FAQ document.
The takeaway? Compliance in 2025 requires thinking beyond the physical and being prepared for requests that are emotional, flexible, and temporary—but no less protected under the law.
The Cost of Getting It Wrong
Failing to meet pregnancy accommodation compliance in 2025 can cost far more than just legal fees. While many employers assume the risk is low unless an employee files a formal complaint, the true danger lies in how quickly a small oversight can escalate into a costly claim—or a reputation-damaging incident.
Recent cases show that violations under the Pregnant Workers Fairness Act (PWFA) and state-specific laws like New York’s Labor Law § 196-b are not being treated lightly. In some cases, companies have paid six-figure settlements for denying reasonable accommodations, such as time off for morning sickness or a modified work schedule during pregnancy. With the EEOC actively investigating and pursuing enforcement, employers are increasingly under scrutiny, even when the original complaint seems minor.
But the financial hit isn’t limited to court judgments. An Equal Employment Opportunity Commission (EEOC) charge—even one that doesn’t result in a lawsuit—can lead to increased Employment Practices Liability Insurance (EPLI)premiums, unbudgeted legal costs, and staff turnover due to poor morale. In some cases, mishandled accommodations have also sparked internal resignations, loss of client trust, and negative online reviews, especially in industries where professional reputation is everything.
In states like New York, failure to offer separate, paid prenatal care leave can also open the door to wage and hour claims. These can be pursued by state labor departments or in as a class action, amplifying exposure.
For context, the U.S. Chamber of Commerce notes that the average employment lawsuit costs over $160,000 to defend and settle. When it comes to pregnancy-related claims, the reputational and operational costs often far exceed that number.
Building a Compliant System—Without Breaking the Bank
Pregnancy accommodation compliance in 2025 doesn’t require a full legal department or expensive HR software overhaul. What it does require is intentional structure, clear documentation, and policies that reflect the evolving legal landscape. Too often, professional service firms believe that legal compliance is either “all or nothing”—but the most effective strategies are those that are both scalable and sustainable.
Start with the handbook. If your policies haven’t been updated since before 2023, they likely don’t reflect the PWFA’s broader scope—or New York’s new prenatal care leave requirements. Including these provisions isn’t just about legal protection; it’s about setting the tone for how pregnancy-related requests will be handled across the firm.
Next, train managers. Many violations stem not from malice but from misunderstanding. Managers must know when the interactive process is triggered, what phrases could imply denial of rights, and how to recognize accommodation requests even when they aren’t formally worded. A 30-minute annual training can prevent months of legal fallout.
Another critical step: separate tracking for prenatal care leave. In New York, these 20 hours of paid prenatal leave are not interchangeable with sick time or PTO. A low-cost solution is creating a separate category in your existing payroll or time-tracking software. Avoiding costly misclassification claims often starts with this one change.
Finally, create a centralized intake process. Accommodation requests should be logged, evaluated consistently, and documented—regardless of outcome. The Society for Human Resource Management (SHRM) offers guidance on intake procedures that reduce bias and ensure uniformity.
Compliance doesn’t need to be complicated—it just needs to be deliberate.
The Ideal Outcome: What Compliance Actually Looks Like in 2025
Achieving pregnancy accommodation compliance in 2025 isn’t just about avoiding liability—it’s about creating a workplace environment that builds trust, reduces turnover, and enhances operational resilience. The firms that handle accommodations well don’t just “check the box”—they embed clarity, consistency, and compassion into their processes.
A compliant accommodation system includes five key elements:
- A straightforward request process that does not require employees to navigate red tape or disclose more medical detail than necessary.
- Timely, documented responses that show the employer is actively engaging in the interactive process.
- Flexibility in execution, especially around scheduling, remote work, or reduced workloads.
- Proactive leave tracking, particularly for states like New York that now require separate prenatal leave balances.
- Consistent communication, including regular check-ins and adjustment of accommodations if conditions change.
Consider a scenario where a mid-level manager requests a modified schedule to attend weekly prenatal appointments. A compliant firm recognizes that New York law entitles her to 20 hours of paid prenatal care leave, logs her request in a central system, confirms coverage for the impacted time blocks, and updates her leave balance transparently. There’s no ambiguity, no delay, and no retaliation—only process.
The broader business benefit? A workplace where employees don’t feel forced to choose between health and career. That matters in professional environments where top talent is hard to retain.
For more best practices, the Department of Labor offers examples of proactive compliance strategies under current laws.
True compliance is proactive, consistent, and built for the real world—not just the legal manual.
Common Employer Mistakes (That Are Now Lawsuit Triggers)
Even well-meaning companies are making costly errors when it comes to pregnancy accommodation compliance in 2025. What’s changed is not just the law—but the lowered threshold for what constitutes a violation. Many of these mistakes stem from outdated assumptions or inconsistent practices, not outright defiance of the rules. But intent won’t protect against liability.
“They can just use sick leave, right?”
This is one of the most common misconceptions, especially in New York. Under Labor Law §196-b, prenatal care leave is now a distinct category of paid leave. Employers who blend it with sick time risk wage-and-hour violations, which can trigger state labor audits and class action exposure.
“We’re too small for this to apply to us.”
Many professional service firms assume federal thresholds apply across the board. But laws like the PWFA apply to employers with 15 or more employees, and state laws in New York and New Jersey often cover employers with as few asone or 4 employees. Compliance isn’t just for the big guys.
“No one’s ever complained.”
Silence isn’t safety. Many employees wait to file complaints until after they’ve resigned or been terminated—making earlier decisions subject to scrutiny. A manager’s dismissive response to an informal accommodation request can become evidence of discrimination months later.
“HR software handles that.”
Automated systems can help—but they don’t know how to recognize an accommodation request that’s made in conversation, or how to apply the interactive process. Technology is a tool, not a shield.
For a breakdown of specific legal triggers and how they’re interpreted, review the EEOC’s enforcement guidance.
Avoiding these mistakes doesn’t require perfection—just informed, documented, and proactive practices.
FAQs: What Employers Are Asking in 2025
The evolving landscape of pregnancy accommodation compliance in 2025 has left many employers with more questions than answers. Here are some of the most pressing—and least understood—questions being asked by professional service firms navigating this new terrain:
- What is pregnancy accommodation compliance in 2025?
It refers to the employer’s responsibility to provide reasonable accommodations to employees for pregnancy, childbirth, and related medical conditions, in compliance with the PWFA, ADA, FMLA, and applicable state laws like NY Labor Law §196-b.
- What qualifies as a pregnancy-related accommodation?
Accommodations now extend beyond physical tasks and include mental health needs, leave for pregnancy loss, and flexible scheduling for prenatal visits or treatment.
- Are employers required to provide paid leave for prenatal appointments?
Yes—in New York, employers must provide up to 20 hours of paid leave annually for prenatal care, separate from sick leave or PTO.
- Can a manager deny a request if it seems minor?
No. Even “minor” requests trigger a legal duty to engage in the interactive process. Failure to do so is often viewed as a per se violation.
- Is documentation always required from the employee?
Not necessarily. The EEOC states that employers should not automatically request documentation unless it is reasonable under the circumstances. See the EEOC guidance for specific examples.
- How do I handle overlapping requests—for example, NY prenatal leave and FMLA?
They must be tracked and administered separately. Bundling these leaves can create legal exposure under both federal and state law.
Proactive answers to these questions are essential for avoiding preventable violations and reinforcing a culture of compliance.
Conclusion: Stop Guessing—Start Preparing
Pregnancy accommodation compliance in 2025 is not a “nice-to-have”—it’s a legal necessity with steep consequences for getting it wrong. A single misstep by a manager. A missed update in your handbook. A failure to track prenatal leave separately. These aren’t small errors—they’re lawsuit triggers. And in today’s enforcement climate, regulators and plaintiffs’ attorneys are watching.
What keeps employers up at night isn’t the paperwork—it’s the uncertainty. What if an employee asks for something that’s not in writing? What if a partner makes a comment that’s taken the wrong way? What if your firm is blindsided by a claim you never saw coming?
The risk isn’t theoretical. It’s already happening to businesses that thought they were covered.
But it doesn’t have to be your story.
Let’s fix the gaps now—before they become front-page problems. Schedule a complimentary discovery call to review your current policies, uncover hidden risks, and create a clear path to full compliance. Peace of mind starts here.
Information contained in this blog is provided for informational purposes and does not constitute legal advice or opinion. You should consult with an attorney regarding the specifics of your matter or legal issue.
The post The New Pregnancy Accommodation Rules You Need to Know in 2025 first appeared on Morea Law LLC.