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Page count: 25

In both the United States and Canada, the concept of reasonable accommodation first emerged in equality law as a means of handling religious diversity. It was then applied to other grounds of discrimination, most notably disability. In the European Union, the evolution of antidiscrimination law is following a different path: a duty of reasonable accommodation was for the first time established by the 2000 Employment Equality Directive (or Directive 2000/78/EC) but only with respect to disability. Nonetheless, the question whether a right to reasonable accommodation can be derived from the prohibition of discrimination based on religion laid down by the same Directive, or, alternatively, whether such right should be recognized in future European legislation is becoming increasingly salient.