Managing Religious Accommodations During the December Holiday Season

International businesses operating in the United States face a unique challenge: managing a workplace where employees celebrate different holidays with equal enthusiasm and receive equal legal protection. While Christmas dominates the American cultural landscape, US employment law requires you to accommodate all religious observances equally during this busy season.

If you’re coming from a country where Christmas is the only recognized December holiday, or where religious accommodation is discretionary, understanding US requirements is essential. This guide will help you navigate the December holiday season while staying compliant with federal law and creating an inclusive workplace.

The Legal Reality: Christmas Isn’t the Only Holiday That Matters

December 25th is a federal holiday in the United States, and most businesses close for Christmas. But here’s what international employers often miss: giving employees Christmas off doesn’t fulfill your legal obligation to accommodate other religious observances. Under Title VII of the Civil Rights Act, you must provide reasonable accommodation for all sincerely held religious beliefs, not just Christian ones.

This means that while Christmas might be built into your company calendar, Jewish employees observing Hanukkah, Muslims celebrating Mawlid al-Nabi, or Hindus observing various December festivals have the same legal right to accommodation. You cannot say “we already give Christmas off, so that’s enough holidays.” That’s textbook religious discrimination under US law.

The legal standard is straightforward: you must accommodate religious observances unless doing so creates substantial hardship for your business operations. Inconvenience doesn’t count. Busy season doesn’t count. The fact that multiple people want time off doesn’t count. You need to find a way to accommodate, even during your busiest time of year.

For more information on your legal obligations, visit the EEOC’s religious discrimination guidance. You can also review the Department of Labor’s information on workplace religious accommodation. If you need help developing compliant policies, Foothold America’s HR Compliance Services can provide expert guidance for international employers.

Understanding December’s Religious Landscape

Christmas on December 25th is obvious, but it’s far from the only significant religious observance this month. Hanukkah, the Jewish Festival of Lights, typically falls in December (dates vary based on the Hebrew calendar). While not the most important Jewish holiday, Hanukkah is culturally significant, and some families request time off for celebrations, particularly the first night.

Kwanzaa runs from December 26th through January 1st and celebrates African American culture and heritage. While not strictly religious, it’s observed by many African American employees and may warrant accommodation under the same principles as religious holidays. Some employees observe the entire week, while others focus on specific days.

The Islamic calendar is lunar, so dates vary, but Mawlid al-Nabi (the Prophet’s birthday) sometimes falls in December. Muslim employees may request this day for religious observance. Additionally, daily prayer requirements continue regardless of the season, so the accommodation needs you’ve handled all year remain relevant. Learn more about accommodating Muslim employees from the EEOC’s guide on religious garb and grooming.

December also includes observances from other faiths: Bodhi Day for some Buddhist traditions (December 8th), Feast of Our Lady of Guadalupe for many Latino Catholics (December 12th), and Winter Solstice celebrations for various pagan and indigenous traditions. The key principle is that you cannot dismiss requests because you’re unfamiliar with the observance or because it’s not “mainstream.”

The December Dilemma: When Everyone Wants Time Off

The biggest challenge for international employers in December is managing competing requests for time off. Between Christmas, Hanukkah, Kwanzaa, New Year’s, and year-end vacation requests, you may have a significant portion of your workforce wanting time away simultaneously. But busy season doesn’t excuse you from accommodation obligations.

Here’s how to handle it legally: Religious accommodation requests take priority over discretionary vacation requests. If an employee needs December 26th off for Kwanzaa and another employee wants it off to extend their Christmas vacation, the religious request comes first. This isn’t favoritism; it’s legal compliance.

For Christmas itself, since it’s a federal holiday, you likely have the day covered in your standard calendar. But if you run a business that operates on federal holidays (healthcare, hospitality, retail, emergency services), you need to be especially careful. You cannot require only non-Christian employees to work on Christmas while giving Christian employees automatic preference. Read more about managing holiday scheduling for international businesses.

The fair approach is to rotate holiday coverage or offer premium pay for working holidays. Make it clear that working Christmas is not punishment and that Christian employees are equally in the rotation. Better yet, ask for volunteers before assigning anyone, and consider offering incentives like double-time pay or extra PTO for those who work.

When multiple employees request the same non-Christmas day off for religious reasons, treat it like any competing vacation request situation: first-come, first-served is acceptable, or rotating priority year to year. What you cannot do is deny all religious requests just because you’re short-staffed. Accommodate as many as possible and be transparent about your decision-making process.

Creating a Fair December Holiday Policy

The best approach is proactive planning rather than reactive crisis management. In November, communicate clearly with your team about December scheduling. Remind employees that religious accommodation is available and explain how to request it. Set a reasonable deadline for requests so you can plan coverage.

Consider offering floating holidays that employees can use for religious observances of their choice rather than only recognizing Christian holidays. For example, instead of giving both Christmas and the day after Christmas off by default, you might close only on Christmas but give employees two floating holidays they can use for their own religious or cultural celebrations. This approach treats all employees more equitably. Learn more about creating inclusive policies in our guide to building culturally intelligent US teams.

If you run a customer-facing business that must stay open during December, build your schedule with accommodation in mind from the start. Don’t create a schedule based on Christian holidays only and then scramble when employees request other accommodations. Ask early in the season who needs accommodation and build those needs into your initial schedule.

Be transparent about your policies. If you provide paid time off for Christmas, explain whether employees who don’t celebrate Christmas can take paid time off for their own holidays or if they need to use vacation time. Consistency matters. You can’t pay Christian employees for Christmas while requiring others to use PTO or take unpaid leave for their holidays. For help developing fair leave policies, consult the Society for Human Resource Management’s resources on religious accommodation.

What International Employers Often Get Wrong

The biggest mistake international employers make is assuming Christmas is universal. In many countries, Christmas is simply “the holiday” and everyone participates culturally even if not religiously. The US is different. With significant Jewish, Muslim, Hindu, Buddhist, and non-religious populations, you cannot assume Christmas is meaningful to all employees.

Don’t hold mandatory events on religious holidays. If your company party is on Christmas Eve or during Hanukkah, you’re effectively excluding employees who observe those holidays. Schedule year-end celebrations in early December or mid-January when they don’t conflict with major observances. If you must hold events during the season, make attendance truly optional. For more guidance on inclusive workplace culture, visit our article on navigating US business culture for foreign companies.

Avoid “Christmas bonus” language if the bonus is for all employees regardless of religion. Call it a “year-end bonus” or “holiday bonus” instead. This seems minor but reflects inclusive thinking. Similarly, “holiday party” is more inclusive than “Christmas party” if you expect all employees to attend.

Don’t pressure employees to participate in Secret Santa, Christmas card exchanges, or other Christian-focused activities. Make participation optional and offer alternatives. Better yet, create traditions that celebrate your team’s diversity rather than assuming one religion’s practices should apply to everyone.

Stop saying “Merry Christmas” to all employees and customers. “Happy Holidays” or “Season’s Greetings” acknowledges that different people celebrate different things. This isn’t political correctness; it’s recognizing reality. If someone tells you they celebrate Christmas, then wish them Merry Christmas. Otherwise, keep it inclusive.

Looking Ahead: New Year and Beyond

As December ends, remember that not all cultures celebrate New Year on January 1st. Chinese New Year (Lunar New Year) falls in late January or February and is significant for many Asian employees. Vietnamese, Korean, and other cultures observe Tet and similar celebrations at the same time. You can find dates for these holidays at the US State Department’s cultural calendar.

If an employee requests time off for Lunar New Year in February, apply the same accommodation principles you used in December. Just because you’re unfamiliar with the celebration doesn’t make it less legitimate. Many Asian cultures consider Lunar New Year more significant than the Western New Year.

Similarly, be aware that some religious traditions have different calendar years. The Islamic New Year (Hijri New Year) follows a lunar calendar and falls at different times. Jewish New Year (Rosh Hashanah) typically occurs in September or October. These are the actual “new year” for those employees, not January 1st. For a comprehensive overview of diverse religious observances, check out the Interfaith Calendar.

The principles you apply in December should guide you year-round. Religious accommodation isn’t seasonal. The only difference is that December highlights the need because Christian holidays dominate American culture while other religious observances happen simultaneously. Use this season as an opportunity to evaluate whether your policies truly accommodate diverse employees. Read our article on year-round religious accommodation best practices for more guidance.

How Foothold America Can Help Your Business

Managing religious accommodations during the December holiday season is complex, especially for international employers unfamiliar with US religious diversity and employment law. Foothold America specializes in helping foreign businesses navigate exactly these challenges.

Our HR compliance services include policy development for religious accommodations tailored to your business. We provide manager training on handling requests appropriately, with special attention to helping international managers understand how US law differs from practices in their home countries. We offer guidance on specific accommodation scenarios when you’re unsure how to proceed.

If you’re struggling with December scheduling, competing requests, or questions about what you’re legally required to do, our team can provide immediate guidance. We help you balance business needs with legal obligations so you can get through the busy season without compliance issues.

Beyond just December, we provide ongoing HR support through our Employer of Record services and PEO+ services. We handle all aspects of HR, payroll, benefits, and compliance so you can focus on growing your business in the American market. Learn more about how we support European companies expanding to the US or explore our US entity setup services.