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.
A housing accommodation request asks a landlord, property manager, association, housing authority, or other provider to change a rule because the change is needed for a person with a disability to use and enjoy the home.
This is general information, not a substitute for advice about a particular housing dispute.
Step 1: Identify the rule that must change
Be specific. Examples include:
- permission to keep an animal despite a no-pets rule;
- an exception to a size, species, breed, or number limit;
- permission to use a common area with the animal;
- waiver of a pet-related fee;
- additional time to submit documentation;
- a different reasonable rule that allows the animal-related need to be met.
A request is easier to evaluate when the provider knows exactly what is being requested.
Step 2: Identify the disability-related need
The Fair Housing Act turns on disability and necessity. The ESA label by itself carries no legal weight.
The request should explain, in an appropriately limited way:
- that the person has a disability under applicable law;
- the relevant limitation affecting use or enjoyment of the home;
- how the requested accommodation helps address that limitation;
- why the accommodation is needed rather than merely preferred.
A diagnosis does not always need to be disclosed. The provider may need enough reliable information to understand the disability-related connection.
Step 3: Explain the animal's role and training
Under HUD's May 2026 Fair Housing Act enforcement guidance, training is central. The request should accurately describe:
- the work or tasks the animal has been trained to perform;
- who trained the animal, if relevant;
- how the trained behavior relates to the disability;
- whether the animal instead provides support through its presence without task training.
Do not invent or exaggerate training. A purchased certificate or vest is not proof that an animal performs disability-related work.
For an untrained ESA, identify whether state or local law provides protection and whether Section 504 may apply.
Step 4: Put the request in writing
A verbal request can sometimes be legally sufficient, but a written request creates a clear record.
Include:
- the tenant or applicant's name and unit or application information;
- the accommodation requested;
- a brief disability-related explanation;
- the animal's species and identifying information;
- a description of disability-related training, if any;
- supporting documentation, when needed;
- a request for a written response;
- a reasonable way to contact the requester.
Do not include unnecessary medical records, detailed therapy notes, or unrelated health information.
Step 5: Use reliable documentation
When the disability and need are not obvious, reliable documentation may be helpful or necessary.
The professional should have a legitimate basis for the opinion. Depending on state law and professional scope, that may involve a clinical relationship, assessment, licensure in the relevant jurisdiction, and knowledge of the person's functional limitations.
A useful letter generally explains:
- the professional's credentials and relationship to the person;
- that the person has a disability, without unnecessary detail;
- the relevant functional limitation;
- the disability-related role of the animal;
- the specific accommodation supported;
- the basis and date of the opinion;
- any limits on the opinion, including lack of animal evaluation.
A letter cannot create a legal right that the governing law does not recognize. See ESA Letters and Documentation.
Step 6: Check other applicable laws
Before submitting the request, check:
- state fair-housing law;
- city or county civil-rights ordinances;
- Section 504 coverage;
- public-housing or voucher rules;
- college-housing policy;
- condominium or homeowner-association law;
- state ESA-documentation statutes.
A local fair-housing organization may help identify the correct rules. HUD lists state and local fair-housing agencies and FHIP nonprofit organizations.
Step 7: Cooperate with reasonable follow-up
A provider may ask for clarification when necessary information is missing. Respond in writing and keep the exchange focused on the accommodation.
A person can ask:
- what specific information is missing;
- why the information is needed;
- whether a less intrusive document would be sufficient;
- whether an interim accommodation is available;
- whether an alternative accommodation would address the concern.
Step 8: Keep records
Save:
- the lease and animal policies;
- the original request;
- letters and forms;
- emails and text messages;
- dates and summaries of conversations;
- notices, fees, threats, or denials;
- animal training and behavior records;
- veterinary and licensing records;
- evidence of state or local law.
Do not secretly record conversations without checking state recording law.
Step 9: Continue meeting ordinary responsibilities
Unless advised otherwise, continue paying rent and following lease terms that are not part of the disputed accommodation. Keep the animal under control and address behavior, sanitation, or damage concerns promptly.
A request does not excuse actual damage or unsafe conduct.
A simple request structure
I am requesting a reasonable accommodation because of a disability. I ask for an exception to [identify rule] so that I may live with [animal]. The accommodation is needed because [brief functional explanation]. The animal is trained to [describe tasks], which relates to my disability by [brief explanation]. Supporting information is attached. Please respond in writing and let me know if specific additional information is needed.
For an untrained ESA, the wording should not falsely claim training. The requester should identify any broader state, local, or program protection being relied on.
Worked example: a written request
The details below are fictional and should be adapted to the person's actual circumstances and governing law.
Subject: Request for a reasonable accommodation
I live in Apartment 3B and am requesting an exception to the building's no-animals rule because of a disability. My dog, Miso, is trained to interrupt a specific repetitive behavior and lead me to a quiet place when symptoms begin. These actions help me remain safely in my home. A letter from my treating clinician is attached and explains the disability-related need without disclosing unrelated medical information.
Miso is licensed, vaccinated, and under my control. Please confirm receipt and tell me in writing if you need specific additional information to evaluate the request. I would appreciate a written decision by August 7 because my current temporary animal-care arrangement ends that week.
Why this works: it identifies the rule, the requested change, the disability-related connection, the animal's actual training, and a practical deadline. It avoids a long medical history and does not claim rights the writer cannot establish.
Example of a reasonable follow-up from a housing provider
We received your request and have not made a decision. The material provided confirms a disability-related need but does not describe the task training mentioned in your request. Please provide a brief description of the trained action and how it relates to the limitation. Do not send complete medical records. We will hold the request open until August 14.
A follow-up should identify the missing point, request no more than is reasonably needed, and leave room for clarification.
When the animal is not task trained
An untrained ESA request should never copy the training language from the example above. Where a verified state, local, or program rule protects an untrained support animal, the request can identify that authority and accurately explain how the animal's presence addresses the disability-related limitation. The clinician's documentation should support that connection without claiming the animal performs trained work or tasks.
For definitions of recurring terms, see the plain-language glossary.
Sources
- 42 U.S.C. § 3604(f)(3)(B)
- 24 C.F.R. § 100.204
- U.S. Department of Justice and HUD, 2004 Joint Statement on Reasonable Accommodations (historical background guidance)
- HUD, May 22, 2026 Animal-Accommodation Enforcement Guidance
- HUD, Report Housing Discrimination
- Younggren JN et al. Emotional Support Animal Assessments: Toward a Standard and Comprehensive Model
- Federal Register, Notification of Withdrawal of Fair Housing and Equal Opportunity Guidance Documents, 91 Fed. Reg. 17291 (Apr. 6, 2026)
- HUD, Fair Housing Assistance Program Agencies
- HUD, Contact a Fair Housing Initiatives Program Organization