Treat any request to change a rule, policy or service because of a disability as a reasonable accommodation request, even if it arrives by text and never uses those words. Answer promptly, ask only for the information HUD allows, charge no fee, and grant it unless it would impose an undue burden or fundamentally change your operation. This is information, not legal advice.
What counts as a reasonable accommodation request?
A reasonable accommodation is a change to a rule, policy, practice or service that a person with a disability needs to have an equal opportunity to use and enjoy a home. HUD's rule at 24 CFR 100.204 makes it unlawful to refuse one, and its own examples are ordinary: a guide dog in a no pets building, a reserved parking space near the unit.
The trigger is lower than most teams assume. The 2004 HUD and DOJ Joint Statement on Reasonable Accommodations says a provider has notice when a person, a family member or someone acting for them asks for a change because of a disability, "even if the words 'reasonable accommodation' are not used." An oral request counts. A request that skips your form counts. You may keep a form, but you may not refuse a request because someone did not use it.
What can a landlord ask before approving one?
It depends on what you can already see. If both the disability and the need are obvious, you ask for nothing more. If the disability is obvious but the link to the request is not, you may ask only about the link.
When neither is obvious, the Joint Statement allows reliable information that does three things: confirms the person meets the legal definition of disability, describes the accommodation, and shows how the two connect. A credible statement from the person can be enough, and so can proof that someone under 65 receives SSI or SSDI. The statement says medical records or detailed information about the condition are usually not necessary, and a diagnosis is not something you get to ask for.
When can a landlord say no?
The Joint Statement lists four grounds. The person does not have a disability. There is no disability-related need for the change. Granting it would impose an undue financial and administrative burden. Or it would fundamentally alter the nature of your operation.
Undue burden is decided case by case, and the guidance expects a conversation about alternatives. HUD's own example is a small building whose staff are on site twice a week: daily trash pickup at the tenant's door may be too much, but a can placed where the tenant can reach it is not, and that alternative must be granted. If no agreement comes out of that discussion, the statement treats it as a denial, which the tenant can take to HUD or a court.
How fast does a landlord have to respond?
There is no fixed number of days in federal law, and that is the trap. The Joint Statement says "an undue delay in responding to a reasonable accommodation request may be deemed to be a failure to provide a reasonable accommodation." A request that sits in a shared inbox for three weeks can become a refusal nobody decided to make. Check state and city rules too.
Can you charge a fee or a deposit for an accommodation?
No. Under question 11 of the Joint Statement, housing providers may not require extra fees or deposits as a condition of granting an accommodation. Where an assistance animal is the accommodation, the Joint Statement's own example rules out a fee or deposit for keeping it. Actual damage can still be charged, as for any tenant.
What should a property management team set up?
- One written process, with a form offered but never required.
- A rule that any message mentioning a disability-related need is routed to a named person the same day, whatever channel it came in on.
- A response target in days, logged, so a slow week cannot turn into a denial.
- A record of each request, the conversation and the outcome.
Step two is where automated leasing helps or hurts. LetHub is AI leasing software for property managers: it answers rental inquiries by text, chat, email and phone in about 30 seconds, day and night, qualifies renters, books tours and runs ID-verified self-showings. A setup like that should flag an accommodation request and hand it to a person with the conversation attached, never answer it on its own.
FAQ
Does a tenant have to put an accommodation request in writing?
No. HUD and DOJ say providers must consider oral requests and requests that do not use the provider's form.
Can a landlord ask for a doctor's note?
Only when the disability or the need is not obvious, and only for what verifies the disability and links it to the request. A credible statement or proof of SSI or SSDI under 65 can be enough, and medical records are usually not needed.
Is a reasonable accommodation the same as a reasonable modification?
No. An accommodation changes a rule or service, such as a parking assignment or a no pets policy. A modification is a physical change to the unit, covered in reasonable modification requests.
To see how an AI leasing agent routes a request it should not answer to your team, book a demo.
