Employment Rights by Country
All disabled people have the right to work on an equal basis with others. The UN Convention on the Rights of Persons with Disabilities (CRPD) Article 27 affirms the right to work, including the right to reasonable accommodation in the workplace. The CRPD sets an international standard; how enforceable it is for an individual depends on whether and how each country has written it into national law (see your country below).
This page centers disabled people’s expertise navigating employment rights in different countries.
Where Are You?
Section titled “Where Are You?”Jump to your country or region:
Universal Principles
Section titled “Universal Principles”Your Rights at Work
Section titled “Your Rights at Work”Under international human rights frameworks, disabled workers have the right to:
Non-discrimination: Can’t be refused a job, fired, demoted, or treated differently because of disability.
Reasonable accommodation: Employers must provide adjustments that allow you to do your job, unless it causes undue hardship.
Equal pay and benefits: Same pay for same work; same access to benefits.
Privacy: Your medical information should be confidential.
Freedom from harassment: Protection from disability-related harassment.
What “Reasonable Accommodation” Means
Section titled “What “Reasonable Accommodation” Means”Accommodations are changes to the job, workplace, or work practices that remove barriers. Examples:
- Flexible scheduling
- Modified duties
- Assistive technology
- Physical accessibility
- Remote work options
- Additional breaks
- Modified supervision
- Job restructuring
- Reassignment to vacant position
Accommodation is interactive—you and your employer work together to find solutions.
United States
Section titled “United States”Legal Framework
Section titled “Legal Framework”Americans with Disabilities Act (ADA) Title I: Covers employers with 15+ employees. Prohibits discrimination and requires reasonable accommodation.
Section 504 of the Rehabilitation Act: Covers federal government and employers receiving federal funds. No minimum size.
State laws: Many states have stronger protections (lower employer thresholds, broader definitions).
Your Rights
Section titled “Your Rights”Hiring: Employers can’t ask about disability before making a job offer. They can ask if you can do essential job functions.
On the job: You’re entitled to reasonable accommodation unless it causes “undue hardship.” Employers must engage in an “interactive process” to find accommodations.
Termination: Can’t be fired because of disability. If fired for performance, the question is whether accommodation would have addressed the issue.
Requesting Accommodations
Section titled “Requesting Accommodations”- Tell your employer you need an adjustment because of a disability (you don’t have to use the word “accommodation”)
- Engage in interactive process to identify effective accommodations
- Provide documentation if requested (limited to what’s needed to establish disability and need)
- Get accommodation in writing (recommended)
If Accommodations Are Denied
Section titled “If Accommodations Are Denied”- Ask for written explanation
- Propose alternatives
- File internal complaint/grievance
- File with EEOC (within 180-300 days depending on state)
- Consult with an employment attorney
Disclosure
Section titled “Disclosure”Disclosure is your choice:
- Don’t have to disclose during application (with some exceptions)
- May need to disclose to get accommodations
- Consider timing: Some disclose after job offer; some wait until needed
- Weigh risks and benefits: Discrimination happens, but so does successful accommodation
Who’s Organizing
Section titled “Who’s Organizing”Disability:IN works with businesses on disability inclusion.
National Organization on Disability focuses on employment.
EARN (Employer Assistance and Resource Network) provides employer resources.
Job Accommodation Network (JAN) provides free consultation on accommodations.
Canada
Section titled “Canada”Legal Framework
Section titled “Legal Framework”Canadian Human Rights Act: Covers federally regulated employers. Prohibits discrimination based on disability.
Provincial Human Rights Codes: Each province has its own code covering most employers.
Employment Equity Act: Requires federally regulated employers to take positive measures for designated groups including disabled people.
Your Rights
Section titled “Your Rights”Similar to the US:
- Non-discrimination in hiring, employment, termination
- Duty to accommodate to the point of “undue hardship”
- Right to request accommodation
- Harassment protection
Duty to Accommodate
Section titled “Duty to Accommodate”Canadian courts have established strong duty to accommodate:
- Must be individualized
- Employer must investigate options
- Can’t refuse without proving undue hardship
- Employee must cooperate in finding solutions
Filing Complaints
Section titled “Filing Complaints”File with the relevant human rights commission:
- Federal: Canadian Human Rights Commission
- Provincial: Provincial human rights tribunal/commission
Resources
Section titled “Resources”- Canadian Human Rights Commission: chrc-ccdp.gc.ca
- Provincial human rights bodies
- Disability organizations in your province
United Kingdom
Section titled “United Kingdom”Legal Framework
Section titled “Legal Framework”Equality Act 2010: Prohibits discrimination based on disability. Covers all employers (no size threshold).
Your Rights
Section titled “Your Rights”Reasonable adjustments: Employers must make reasonable adjustments where disabled person would otherwise be at substantial disadvantage.
Non-discrimination: Protection throughout employment—recruitment, terms, dismissal.
Discrimination arising from disability: Employer can’t treat you unfavorably because of something arising from your disability (unless justified).
Harassment and victimization: Protected from harassment and from retaliation for asserting rights.
Types of Discrimination
Section titled “Types of Discrimination”The Equality Act covers:
- Direct discrimination: Treating someone less favorably because of disability
- Indirect discrimination: Policies that disadvantage disabled people
- Discrimination arising from disability: Unfavorable treatment related to disability
- Failure to make reasonable adjustments
- Harassment and victimization
Requesting Adjustments
Section titled “Requesting Adjustments”- Tell your employer you need adjustments
- Employers should proactively consider adjustments
- Access to Work scheme can fund many workplace adjustments
Access to Work
Section titled “Access to Work”Government program providing:
- Practical support and aids at work
- Help with communication at interviews
- Support workers
- Travel assistance
- Mental health support
Apply through gov.uk or call Access to Work.
Enforcement
Section titled “Enforcement”- Internal processes first (grievance)
- ACAS Early Conciliation (required before tribunal)
- Employment Tribunal within 3 months (less one day)
- Equality Advisory Support Service (EASS) provides advice
Who’s Organizing
Section titled “Who’s Organizing”Disability Rights UK provides employment information and advocacy.
Evenbreak is a job board and employment service run by disabled people.
Business Disability Forum works with employers.
European Union
Section titled “European Union”Framework
Section titled “Framework”EU Employment Equality Directive (2000/78/EC) prohibits discrimination in employment based on disability and requires reasonable accommodation.
Individual countries implement this in their national laws.
Country Highlights
Section titled “Country Highlights”Germany:
- Severely disabled people (50%+ disability rating) have additional protections
- Employers with 20+ employees must employ 5% disabled workers or pay levy
- Integration offices support workplace inclusion
- Right to reasonable accommodation
France:
- Employers with 20+ employees must employ 6% disabled workers or pay contribution
- AGEFIPH (private) and FIPHFP (public) fund workplace accommodations
- MDPH determines disability status
Netherlands:
- Participation Act requires employers to accommodate
- Job coaches and workplace supports available
- Quota system for public employers
Spain:
- The General Disability Rights Law (Royal Legislative Decree 1/2013, which consolidated the former LISMI) requires employers with 50+ employees to reserve 2% of jobs for disabled workers
- Right to reasonable adjustments
- Reservations for certain jobs
Filing Complaints
Section titled “Filing Complaints”Each country has its own enforcement mechanisms—typically labor courts, equality bodies, or ombudsman offices.
Who’s Organizing
Section titled “Who’s Organizing”European Disability Forum advocates at EU level.
National disability organizations in each country work on employment.
Australia
Section titled “Australia”Legal Framework
Section titled “Legal Framework”Disability Discrimination Act 1992 (DDA): Prohibits discrimination in employment based on disability.
Fair Work Act 2009: General employment protections.
State/Territory anti-discrimination laws: Provide additional protections.
Your Rights
Section titled “Your Rights”- Non-discrimination in all aspects of employment
- Right to reasonable adjustments
- Protection from harassment
- Right to equal pay and conditions
Reasonable Adjustments
Section titled “Reasonable Adjustments”Employers must make adjustments unless they cause “unjustifiable hardship.” Factors considered:
- Nature of the adjustment
- Effect on the employer
- Employer’s financial circumstances
- Availability of assistance (like JobAccess)
JobAccess
Section titled “JobAccess”Government-funded service providing:
- Free workplace modification funding (Employment Assistance Fund)
- Advice for employers and employees
- Information about workplace accommodations
Contact: jobaccess.gov.au or 1800 464 800
Disability Employment Services (DES)
Section titled “Disability Employment Services (DES)”Government-funded employment support:
- Job search assistance
- Resume and interview help
- Workplace support
- Ongoing support after placement
Enforcement
Section titled “Enforcement”- Australian Human Rights Commission: Complaints and conciliation
- Fair Work Commission: General employment complaints
- State/Territory tribunals: State law complaints
Who’s Organizing
Section titled “Who’s Organizing”People with Disability Australia (PWDA) advocates on employment issues.
Australian Federation of Disability Organisations (AFDO) works on policy.
Disabled People’s Organisations in each state.
Other Countries
Section titled “Other Countries”CRPD Framework
Section titled “CRPD Framework”If your country has ratified the CRPD, you have international human rights protection for:
- Non-discrimination in employment
- Reasonable accommodation
- Equal pay for equal work
National implementation varies significantly.
Global South Realities
Section titled “Global South Realities”In many countries:
- Employment protections exist on paper but enforcement is weak
- Informal economy is dominant (not covered by employment laws)
- Quota systems exist but aren’t enforced
- Disabled people face high unemployment regardless of laws
- Self-employment and family enterprises may be primary options
Finding Your Rights
Section titled “Finding Your Rights”- Research your country’s disability discrimination law (if one exists)
- Contact national disability organization for guidance
- Connect with ILO (International Labour Organization) resources
- Find disabled people’s organizations who can advise
International Resources
Section titled “International Resources”- ILO Global Business and Disability Network: Promotes disability inclusion
- Disability:IN Global: Resources for businesses
- International Disability Alliance: Advocacy and resources
Intersectionality in Employment
Section titled “Intersectionality in Employment”Disabled People of Color
Section titled “Disabled People of Color”Face compounded barriers:
- Racism and ableism in hiring
- Fewer interview callbacks
- Disproportionate discipline and termination
- Less likely to have accommodations approved
- Wage gaps on multiple dimensions
Disabled Women
Section titled “Disabled Women”Experience:
- Gender and disability pay gaps
- Pregnancy discrimination combined with disability discrimination
- Less likely to be in leadership roles
- Sexual harassment plus disability harassment
LGBTQ+ Disabled Workers
Section titled “LGBTQ+ Disabled Workers”May face:
- Discrimination on multiple grounds
- Less protection in some jurisdictions
- Need for affirming workplaces on both identities
Disabled Workers in Poverty
Section titled “Disabled Workers in Poverty”Face:
- Can’t afford to be unemployed while fighting discrimination
- Less access to legal help
- May accept poor conditions out of necessity
- Transportation and housing barriers to employment
Scenarios: Finding What You Need
Section titled “Scenarios: Finding What You Need””I need accommodations but I’m afraid to ask”
Section titled “”I need accommodations but I’m afraid to ask””You have a legal right to reasonable accommodation. Document your request in writing. Focus on what you need to do the job, not your diagnosis. Many accommodations are low or no cost. Know your rights before you ask.
”My employer denied my accommodation request”
Section titled “”My employer denied my accommodation request””Ask for written explanation. Propose alternatives. If no resolution, file a complaint with relevant agency (EEOC in US, human rights commission elsewhere). Consult with an employment attorney. Document everything.
”I’m being harassed at work because of my disability”
Section titled “”I’m being harassed at work because of my disability””Document all incidents. Report through internal channels. File complaint with relevant agency if internal resolution fails. Know that retaliation for reporting is also illegal.
”Should I disclose my disability in my application?”
Section titled “”Should I disclose my disability in my application?””Usually not required or advisable at application stage. Wait until after job offer to request accommodations in most cases. Consider what works best for your situation.
”I was fired after disclosing my disability”
Section titled “”I was fired after disclosing my disability””This may be illegal discrimination. Document the timeline. File complaint with relevant agency promptly (deadlines are strict). Consult an employment attorney.
Resources
Section titled “Resources”Global
Section titled “Global”- ILO Disability and Work: ilo.org
- International Disability Alliance: internationaldisabilityalliance.org
United States
Section titled “United States”- Job Accommodation Network (JAN): askjan.org (free accommodation consultation)
- EEOC: eeoc.gov
- Disability:IN: disabilityin.org
Canada
Section titled “Canada”- Canadian Human Rights Commission: chrc-ccdp.gc.ca
- Provincial human rights commissions
United Kingdom
Section titled “United Kingdom”- Access to Work: gov.uk/access-to-work
- Equality Advisory Support Service: equalityadvisoryservice.com
- Disability Rights UK: disabilityrightsuk.org
European Union
Section titled “European Union”- European Disability Forum: edf-feph.org
- National equality bodies in each country
Australia
Section titled “Australia”- JobAccess: jobaccess.gov.au
- Australian Human Rights Commission: humanrights.gov.au
Contribute to This Page
Section titled “Contribute to This Page”Have you navigated employment rights as a disabled worker? Fought for accommodations? Have knowledge of your country’s laws?
Share your knowledge: Contribution Form
We especially welcome:
- Country-specific information
- First-hand experiences
- Successful accommodation strategies
- Tips for enforcement
This page centers disabled workers’ expertise. Employment rights exist because disabled people organized and fought for them.