Disability Accommodation Interactive Process Now Codified in the MHRA

Governor Walz signed SF 3210 into law on May 18, 2026, the last day of session. The bill adds a new paragraph (c) to Section 363A.02, subdivision 1, of the Minnesota Human Rights Act which states:

In practical terms, this means that failing or refusing to sit down and discuss an accommodation request — even if you ultimately cannot grant the accommodation — may now give rise to a discrimination claim under the MHRA. For those employers who are covered by the Americans With Disabilities Act, this is not a meaningful change because the duty to engage in the interactive process has been in place for decades. And, even beyond that, having a genuine conversation with an employee about how their impairment affects their work is just good business practice.

Nonetheless, the amendment serves as a good reminder to make sure your managers and HR teams understand the interactive process and are trained to engage in it consistently and in good faith whenever an accommodation request is made.

Wait, That’s It?

The 2026 session did not produce any significant changes to Minnesota Statutes Chapter 181 (the nuts and bolts employment laws, including Earned Sick and Safe Time), 177 (wage and hour) and 268B (Minnesota Paid Leave). Some employers may be disappointed the legislature did not take steps to address the many concerns resulting from the 2025 session but on the other hand, others will gladly take the status quo.

Bottom Line

The headline from the 2026 Minnesota legislative session is clearly the codification of the interactive process requirement in the MHRA’s public policy statement. It is a meaningful development, even for employers who already follow best practices. As always, if you have questions about how these changes affect your organization, please reach out to our team.

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