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ARIZONA STATE SENATE
Fifty-Seventh Legislature, Second Regular Session
employers; medical products; religious exemption
Purpose
Expands the employer COVID-19 vaccine religious exemption to apply to any medical product. Prohibits an employer from inquiring into the veracity of an employee's religious beliefs or discriminating against an employee based on the employee's refusal to take a medical product. Establishes a complaint process through the Attorney General's (AG's) office and authorizes the AG to take corrective action and impose civil penalties on noncompliant employers.
Background
Employers that receive notice from an employee that taking the COVID-19 vaccination conflicts with a sincerely held religious belief, practice or observance must provide the employee a reasonable accommodation, unless the accommodation would pose an undue hardship and more than a de minimus cost to the employer (A.R.S. § 23-206).
A medical product is a drug, device, biological product or product that is a combination of drugs, devices and biological products (42 USC § 287a).
There is no anticipated fiscal impact to the state General Fund associated with this legislation.
Provisions
Medical Product Religious Exemption
2. Prohibits employers from:
a) inquiring into the veracity of an employee's religious beliefs, practices or observances to the extent beyond what is allowed under federal law; and
b) discriminating against an employee regarding employment, wages or benefits based on the employee's refusal to take a medical product.
3. Removes an employer’s ability to deny a religious exemption on the basis that providing a reasonable accommodation would impose more than a de minimis cost.
4. Outlines minimum requirements of an employer's medical product religious exemption form.
5. Requires employers to keep religious exemption claims confidential within the organization, except to the extent necessary to process the exemption, accommodation or other operational necessity.
6. Allows an employer to create a database of religious exemption requests only for internal use, unless otherwise required by law.
Complaints and Violations
7. Allows a terminated employee who was not offered or was denied a religious exemption by their employer to file a complaint with the AG.
8. Stipulates that employers are only required to apply religious exemptions to the extent required under federal law.
9. Requires the AG to investigate all complaints relating to medical product religious exemptions.
10. Requires AG investigations of religious exemption complaints to determine whether:
a) the employer imposed a medical product mandate;
b) the employee was offered and submitted a proper exemption statement; and
c) the employee was terminated as a result of the employer's failure to allow a religious exemption.
11. Requires the AG to notify employers that violate religious exemption requirements of their violation and provide the employer the opportunity to correct the noncompliance within 10 days.
12. Directs the AG to assess a civil penalty of $5,000 on any employer that does not correct noncompliance with medical product religious exemption requirements within 10 days.
Miscellaneous
13. Clarifies that sincerely held religious beliefs, practices or observances includes a sincerely held moral or ethical belief.
14. Makes conforming changes.
15. Becomes effective on the general effective date.
Prepared by Senate Research
January 15, 2026
MM/hk