Federal housing update: HUD withdrew its 2013 and 2020 animal guidance and adopted a narrower Fair Housing Act enforcement standard in May 2026. The statute itself did not change, and other laws may apply. Read the full update.
An ESA letter is a clinician's written opinion that a person has a disability-related need for an animal accommodation. No government agency issues or certifies these letters, and a letter cannot force a landlord, college, airline, employer, or court to approve the animal.
The value of a letter depends on the quality of the evaluation, the professional's qualifications, the accuracy of the opinion, and the law that applies in the particular setting.
What an ESA letter is meant to document
A clinically and legally responsible letter may document:
- that the person has a disability under the applicable legal definition;
- the functional limitation relevant to the requested setting;
- how the animal helps mitigate that limitation;
- why the requested accommodation is needed;
- the clinician's relationship to the person and basis for the opinion;
- the date and scope of the evaluation.
The letter should disclose no more sensitive health information than is reasonably necessary.
What changed in federal housing
HUD's current Fair Housing Act enforcement approach places much more weight on disability-related training than the withdrawn 2020 guidance did. This means:
- a clinician's statement that an untrained animal provides emotional support may no longer be enough for HUD's current Fair Housing Act enforcement standard;
- documentation of disability and need remains relevant;
- accurate information about trained work or tasks has become especially important;
- state law, Section 504, and private court rights may differ;
- clinicians should update templates that cite the withdrawn 2020 notice as current authority.
A letter should not promise federal housing approval.
Who can write an ESA letter?
There is no single nationwide list that answers every setting and state.
Depending on the law and professional scope, documentation may come from a licensed:
- psychologist;
- psychiatrist or other physician;
- clinical social worker;
- professional counselor;
- marriage and family therapist;
- nurse practitioner or other qualified healthcare professional.
State law may require:
- licensure in the patient's state;
- an established professional relationship;
- a minimum period or number of visits;
- a clinical assessment;
- telehealth compliance;
- specific statements or warnings;
- discipline for fraudulent or unsupported letters.
A housing provider may also evaluate whether the source is reliable and has personal knowledge supporting the opinion.
See ESA laws and provider requirements by state for the relationship, evaluation, licensing, and documentation rules covered in our state summaries.
Warning signs of letter mills
Be wary of any letter service that involves:
- guaranteed approval;
- a letter issued after only a short questionnaire;
- no meaningful interaction with a licensed professional;
- no assessment of functional impairment;
- no discussion of risks or animal care;
- a package centered on registration, ID cards, certificates, or vests;
- claims that the letter creates public-access or airline rights;
- a provider who is not licensed where required;
- a letter copied from a template with factual errors;
- a promise that no landlord may ever deny the request.
A legitimate evaluation can still occur by telehealth when lawful and clinically appropriate. The issue is the substance and professional basis of the assessment, not simply whether it occurred online.
What a proper assessment should consider
Professional literature recommends a more complete process than confirming that a person has a diagnosis.
1. Disability and functional impairment
The evaluator should consider whether the condition substantially limits a major life activity under the law being applied and how that limitation affects the requested setting.
A diagnosis alone does not automatically establish disability or necessity.
2. Connection between the animal and the limitation
The evaluator should identify what the animal does or how its presence affects the relevant impairment. The opinion should distinguish a meaningful disability-related effect from ordinary affection, preference, or comfort.
3. Alternatives, risks, and burdens
The assessment may consider:
- whether the animal is likely to help;
- whether animal care could worsen stress or finances;
- allergies, phobias, household conflict, or safety;
- housing stability;
- grief and contingency planning;
- other treatment and support options;
- whether a task-trained service dog is more appropriate.
4. Ability to care for the animal
The person should be able to provide food, exercise, sanitation, veterinary care, supervision, enrichment, and emergency planning.
5. Animal suitability and welfare
Many mental-health professionals are not qualified to certify an animal's health, temperament, or safety. The letter should not claim that the animal is well behaved or suitable for a particular environment unless the professional has a valid basis and appropriate competence.
Veterinary or qualified behavior input may be appropriate.
6. Role conflict and objectivity
A treating clinician may know the patient well but may also feel pressure to advocate. An independent evaluator may be more objective but know less about the person's history.
Professional articles urge evaluators to recognize this tension, gather sufficient information, and avoid treating the requested outcome as predetermined.
What should the letter contain?
There is no universal template. A concise letter may include:
- clinician's name, license, jurisdiction, and contact information;
- date of evaluation and letter;
- nature of the professional relationship;
- statement that the person has a disability under the relevant standard;
- relevant functional limitation without unnecessary diagnosis details;
- description of the animal's disability-related role;
- specific accommodation recommended;
- description of trained work or tasks, when applicable and verified;
- statement of the information on which the opinion is based;
- limits of the clinician's opinion;
- signature and license information.
The letter should avoid legal conclusions outside the clinician's expertise, such as “the landlord is legally required to approve this animal.”
What a letter cannot do
An ESA letter does not automatically:
- make an animal a service animal;
- create public-access rights;
- require an airline to treat the animal as a service animal;
- override animal-control or public-health law;
- excuse dangerous behavior or damage;
- guarantee a housing fee waiver;
- establish that the animal is trained;
- replace a state's documentation requirements;
- bind HUD or a court.
Privacy and verification
A housing provider may seek reliable information needed to evaluate a request when disability or necessity is not apparent. The requester can ask what specific information is needed and why.
Clinicians should obtain appropriate authorization before communicating with a housing provider and should avoid disclosing psychotherapy notes or unrelated medical history.
The housing provider should verify documents without harassing the person, demanding irrelevant records, or contacting a clinician without proper permission.
For definitions of recurring terms, see the plain-language glossary.
Sources
- Younggren JN, Boness CL, Bryant LM, Koocher GP. Emotional Support Animal Assessments: Toward a Standard and Comprehensive Model for Mental Health Professionals
- Younggren JN et al. Examining Emotional Support Animals and Role Conflicts in Professional Psychology
- American Psychological Association, Is That a Pet or Therapeutic Aid?
- American Psychological Association, Using Animals in Therapy
- Hoy-Gerlach J et al. Supporting Rights to Emotional Support Animals as an Accommodation: A Scoping Review of Professional Guidelines for Verifying Eligibility
- HUD, May 22, 2026 Animal-Accommodation Enforcement Guidance
- HUD, September 17, 2025 Withdrawal Notice
- U.S. Department of Justice and HUD, 2004 Joint Statement on Reasonable Accommodations (historical background guidance)
- Federal Register, Notification of Withdrawal of Fair Housing and Equal Opportunity Guidance Documents, 91 Fed. Reg. 17291 (Apr. 6, 2026)