How should a landlord respond to a reasonable accommodation request?

What counts as a request

The Fair Housing Act regulation at 24 CFR 100.204 makes it unlawful to refuse reasonable accommodations in rules, policies, practices or services when they may be needed to give a person with a disability an equal opportunity to use and enjoy a home, including common areas. The 2004 HUD and Justice Department joint statement says a request is made whenever a tenant, a family member or someone acting for them asks for an exception or change because of a disability. It can be oral, and you must consider it even if the tenant does not use your form.

Requests at a small building are usually ordinary:

• A reserved parking space near the entrance (the regulation's own example).
• Moving the rent due date to match when a disability benefit arrives.
• A transfer to a ground-floor unit when one opens.
• Letting a live-in aide stay who is not on the lease.
• Notices in large print, or by email instead of paper.

Animals follow the same rule but have their own recent history at HUD; see assistance animals and pet policies.

A decision guide

1. Is the disability obvious or already known, and is the need for this change obvious? If both are, approve without asking for documents. The joint statement's example is a tenant who uses a walker asking for a closer parking space.
2. If the disability is known but the need is not, ask only for information about the need for this change.
3. If neither is known, you may ask for reliable information that the person has a disability, what they need, and how the two connect. A credible statement from the tenant, proof of disability benefits for someone under 65, or a note from a doctor, a peer support group or another reliable third party can do this. You generally may not ask about the nature or severity of the disability, and medical records are usually not needed.
4. Is the change reasonable? Weigh its cost, your resources, the benefit to the tenant, and whether a cheaper alternative would meet the same need.
5. If you think it is not reasonable, talk with the tenant about an alternative. If an alternative works and is reasonable, you must grant it.
6. Answer in writing and keep the request, your questions, the answer and the date together.

Three rules owners trip on

No fees or extra deposits

The joint statement says you may not charge extra fees or deposits as a condition of an accommodation. You may charge for actual damage the same way you charge every tenant.

Delay counts as a denial

An undue delay in answering may be treated as a refusal. Set yourself a target, such as a reply within a week, and send a short note if you need information.

Modifications are different

A physical change to the unit, such as grab bars or a ramp, is a reasonable modification under 24 CFR 100.203. In a private rental the tenant generally pays for it. You may ask for a description of the work, assurance it will be done properly with permits, and, where reasonable, an agreement to restore the interior at move-out, reasonable wear and tear excepted. You may not raise the security deposit for it, though a restoration agreement may include payments into an interest-bearing escrow account, not exceeding the restoration cost, with interest going to the tenant.

Worked example: moving a due date

Example a made-up tenant pays $1,200 rent due on the 1st, with a late fee of $60 after the 5th. Her disability benefit arrives on the 3rd of each month, and she asks to pay on the 3rd instead. The owner's cost is two days of float on $1,200, and the late fee rule simply moves with the due date to the 7th. The owner approves in writing, updates the lease by addendum, and changes the tenant's due date in the ledger. Charging a fee for the change would not be allowed.

If the same tenant asked to pay on the 20th, the owner could weigh the larger cost, such as a mortgage due on the 1st, and offer an alternative, like a split payment on the 3rd and the 18th, before saying no.

Where the federal guidance stands

In a notice published April 6, 2026, HUD listed guidance documents it withdrew effective September 17, 2025, including its two assistance animal notices. The 2004 joint statement on reasonable accommodations is not on that list. The statute and the regulations above did not change, and the same notice repeats that a person may sue in federal or state court within two years. State laws can add more, so check your state civil rights agency.

Doing it in DoorKeeping

In DoorKeeping, a changed due date or waived fee is a change to the tenant's ledger that waits for your one-tap approval, and the addendum can go out for e-signature. You can email the tenant from DoorKeeping and keep the request and your reply with the property's documents. DoorKeeping gives no legal advice; for a hard case, call a fair housing attorney.

Sources

1. eCFR, 24 CFR 100.204, Reasonable accommodations, read Oct 30, 2026
2. eCFR, 24 CFR 100.203, Reasonable modifications of existing premises, read Oct 30, 2026
3. HUD and U.S. Department of Justice, Joint Statement: Reasonable Accommodations under the Fair Housing Act (May 17, 2004), read Oct 30, 2026
4. HUD, Notification of Withdrawal of Fair Housing and Equal Opportunity Guidance Documents (Federal Register, April 6, 2026), read Oct 30, 2026

Questions

Does a reasonable accommodation request have to be in writing?

No. The joint statement says a request can be oral and must be considered even if the tenant skips your form. Writing helps both sides, so confirm it in writing yourself.

Can I ask what the tenant's disability is?

Generally no. When the need is not obvious you may ask for reliable information that shows a disability and the need for the change, not the diagnosis or medical records.

When can a landlord say no?

When the change would be an undue financial and administrative burden or would fundamentally alter your operations, judged case by case. Even then, discuss an alternative and grant one that works.