Ohio Return to Office Mandate 2026
⚠️Informational only — not legal or tax advice.
Last Updated: December 2025
Applicable Period: 2026 and current employment regulations
Key Characteristic: Executive Order 2025-01D for state employees and at-will employment framework for private sector employers in Ohio
Table of Contents
Introduction
Ohio’s return to office mandate refers to Executive Order 2025-01D issued by Governor Mike DeWine on February 4, 2025, requiring state employees under the Governor’s authority to return to physical office locations no later than March 17, 2025. This executive order applies exclusively to state agencies, boards, and commissions under gubernatorial authority and does not apply to private sector employers or employees.
This guide compiles official information published by the Ohio Civil Rights Commission, Ohio Department of Administrative Services, U.S. Equal Employment Opportunity Commission, and other government agencies regarding Ohio’s return to office mandate, employee rights under Ohio and federal anti-discrimination laws, and reasonable accommodation processes.
Last updated: December 20, 2025
Sources: Executive Order 2025-01D, Ohio Revised Code Chapter 4112, Ohio Civil Rights Commission, EEOC Cleveland Field Office, Americans with Disabilities Act
Applicable Legal Framework - Ohio
1.1 At-Will Employment Doctrine
Ohio is an employment-at-will state. According to the Ohio Supreme Court, in the absence of a written employment agreement or collective bargaining agreement, either the employer or the employee can terminate employment for any reason that is not contrary to law.
According to the Ohio Legislative Service Commission:
“Ohio is an employment-at-will state, which means that, in the absence of a written employment agreement or a collective bargaining agreement, either the employer or the employee can terminate employment for any reason which is not contrary to law.”
Source: Ohio Legislative Service Commission, Members Brief – At-Will Employment
Available at: https://www.lsc.ohio.gov/assets/organizations/legislative-service-commission/files/employment-at-will-and-wrongful-discharge-in-ohio-10014256.pdf
Publication: Ohio General Assembly
Ohio Administrative Code Section 3358:17-9-03 establishes:
“Support staff, regularly scheduled part-time, and casual labor are employed on an ‘at-will’ basis. Either they or the college may end the employment relationship with or without notice and with or without cause.”
Source: Ohio Administrative Code § 3358:17-9-03
Official text available at: https://codes.ohio.gov/ohio-administrative-code/rule-3358:17-9-03
Last updated: Current through December 2025
Exceptions to At-Will Employment:
Ohio law recognizes several exceptions to the at-will employment doctrine:
- Express Contracts: Written employment agreements specifying terms of employment
- Implied Contracts: Circumstances that imply contractual obligations
- Collective Bargaining Agreements: Union contracts governing employment terms
- Public Policy Exceptions: Terminations violating clear public policy
- Statutory Protections: Anti-discrimination and anti-retaliation laws
The Ohio Supreme Court has held that the at-will employment presumption can be overcome through contract, employee handbook provisions, or public policy considerations.
Source: Ohio Supreme Court decisions including Mers v. Dispatch Printing Co., 19 Ohio St.3d 100 (1985)
1.2 Ohio’s Executive Order 2025-01D – Return to Office for State Employees
OFFICIAL EXECUTIVE ORDER
Document: Executive Order 2025-01D
Title: “Return to Office for State of Ohio Employees”
Issued by: Governor Mike DeWine
Date Signed: February 4, 2025
Effective Date: March 17, 2025
Available at: https://governor.ohio.gov/media/executive-orders/executive-order-2025-01d
Official Text – Key Provisions:
According to Executive Order 2025-01D:
WHEREAS, “on March 9, 2020, the State of Ohio took swift action to declare an emergency in response to the COVID-19 pandemic, including permitting certain State of Ohio employees to work remotely”; and
WHEREAS, “on June 18, 2021, the state of emergency declared under 2020-01D ended and State of Ohio employees who had been working remotely began performing their duties at a physical office or facility on a full-time or hybrid basis”; and
WHEREAS, “it is now in the best interest of the citizens of Ohio for State of Ohio employees to complete a return to a physical office or facility to best serve the public and maximize the use of state-owned assets and facilities.”
NOW THEREFORE, the order directs:
Section 1 – Mandatory Return: “State agencies, boards, and commissions under the authority of the Governor (collectively referred to as agency or agencies) shall require all permanent employees to routinely perform their duties in the physical office or facility assigned by their appointing authority, and not routinely from a remote location, no later than March 17, 2025.”
Section 2 – Exceptions Authority: “The Department of Administrative Services (DAS) shall amend applicable policies to reflect the elements of this order and shall include the ability for an appointing authority to grant exceptions they deem necessary. Some examples may include where:
a. The appointing authority has deemed it appropriate to exempt certain limited classifications, field workers or agency employees for whom no reasonable in-office employment is possible, or other compelling situations and has certified those requests to the Director of DAS; or
b. DAS has or assisted the agency in eliminating all or a portion of the agency’s commercial real estate portfolio and new or additional office space would have to be acquired or remodeled at additional cost; or
c. Other exceptions as outlined within the revised DAS policy and subject to the approval of the Director of DAS.”
Section 3 – Limitations and Clarifications: “Nothing in this Executive Order shall be construed to impair or otherwise affect the authority granted to the Governor or an Agency by the Ohio Constitution, Ohio Revised Code, or the Ohio Administrative Code. Nothing in this Executive Order shall be construed to abridge any collective bargaining contracts. Nothing in this Executive Order shall impact managerial discretion due to onsite or localized events such as electrical outages, water outages, security events, weather events, etc.”
Source: Executive Order 2025-01D
Published by: Office of Governor Mike DeWine
Official PDF: https://content.govdelivery.com/attachments/OHIOGOVERNOR/2025/02/04/file_attachments/3154036/Executive%20Order%202025-01D.pdf
Format: PDF
Pages: 2
Who Is Covered:
- State agencies, boards, and commissions under the Governor’s authority
- Permanent state employees who were working remotely or on hybrid schedules
- Approximately 15,400 state employees previously on hybrid or remote work assignments
Who Is NOT Covered:
- Private sector employers and employees
- Offices of elected officials not under the Governor’s authority (Attorney General, Secretary of State, Auditor, Treasurer)
- State employees already working in-office full-time (approximately 65% never worked remotely)
- Field workers and employees for whom no reasonable in-office employment is possible
Source: Ohio Department of Administrative Services, February 2025 data
Implementation Timeline:
- February 4, 2025: Executive Order signed
- March 17, 2025: Compliance deadline – all covered employees required to return to office
- Expiration: Ten (10) calendar days after Governor DeWine’s last day in office, unless rescinded earlier
1.3 No State-Specific RTO Mandate for Private Employers
As of December 20, 2025, the Ohio General Assembly has not enacted specific statutes or executive orders governing return to office mandates for private sector employers.
Legislative Research Conducted:
Website: Ohio Legislature – https://legislature.ohio.gov
Date: December 20, 2025
Search terms: “return to office”, “remote work mandate”, “telework requirements”, “workplace flexibility”
Result: No relevant private sector legislation identified
Private sector employers in Ohio operate under the at-will employment framework subject to:
- Ohio Civil Rights Act (Ohio Revised Code Chapter 4112)
- Americans with Disabilities Act (ADA)
- Title VII of the Civil Rights Act of 1964
- Age Discrimination in Employment Act (ADEA)
- Family and Medical Leave Act (FMLA)
- Contractual obligations (individual or collective bargaining)
- Common law wrongful discharge exceptions
Important Note for Private Employers:
While Executive Order 2025-01D does not apply to private employers, private sector companies remain subject to all applicable state and federal anti-discrimination laws, including requirements to provide reasonable accommodations for employees with disabilities and to refrain from discriminatory or retaliatory employment practices.
Source: Ohio Revised Code Chapter 4112
Available at: https://codes.ohio.gov/ohio-revised-code/chapter-4112
Competent Government Agencies
2.1 Ohio Civil Rights Commission (OCRC)
The Ohio Civil Rights Commission was established July 29, 1959, by the Ohio Legislature to enforce state laws against discrimination.
Contact Information:
Central Office:
Ohio Civil Rights Commission
30 East Broad Street, 5th Floor
Columbus, OH 43215
Telephone: (614) 466-2785
Toll-Free: 1-888-278-7101
TTY: 1-800-750-0750 (English) / 1-888-269-0678 (Spanish)
Email: PACE@civ.ohio.gov
Website: https://civ.ohio.gov/home
Office Hours: Monday – Friday, 8:00 AM to 5:00 PM
Filing Charges: By appointment – effective February 13, 2023, OCRC regional offices are open to the public by appointment to file a charge
Jurisdiction and Function:
According to Ohio Revised Code Chapter 4112, the OCRC receives and investigates charges of discrimination in:
- Employment
- Public accommodations
- Housing
- Credit
- Disability in higher education
Protected Classes under Ohio Law:
- Race
- Color
- Religion
- Sex (including pregnancy)
- National origin
- Disability
- Age (40 and over)
- Ancestry
- Military status
- Familial status (housing)
Source: Ohio Revised Code § 4112.02
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.02
Effective: April 6, 2023
Powers and Authority:
According to Ohio Revised Code § 4112.04, the Commission has statutory authority to:
- Initiate and carry out investigations of discriminatory practices
- Formulate policies to effectuate the purposes of Chapter 4112
- Make recommendations to state agencies and local subdivisions
- Make periodic surveys of discrimination’s existence and effect
- Issue subpoenas, interrogatories, and cease and desist orders
- Hold public hearings
- Collect monetary benefits
Regional Offices:
Cleveland Regional Office:
Lausche State Office Building
615 W. Superior Avenue
Cleveland, OH 44113
Phone: 1-888-278-7101
Cincinnati Regional Office:
Available by appointment
Phone: 1-888-278-7101
Toledo Office:
Available by appointment
Phone: 1-888-278-7101
Dayton Office:
Available by appointment
Phone: 1-888-278-7101
Source: Ohio Civil Rights Commission website
Available at: https://civ.ohio.gov/home
Publications on RTO: The OCRC has not published specific guidance on return to office mandates. General employment discrimination enforcement guidance is available on the OCRC website.
2.2 Ohio Department of Administrative Services (DAS)
The Department of Administrative Services administers state employee policies, including those related to Executive Order 2025-01D.
Contact Information:
Ohio Department of Administrative Services
30 East Broad Street
Columbus, OH 43215
General Information: (614) 466-6511
Website: https://das.ohio.gov
Function Related to RTO:
- Implementation of Executive Order 2025-01D
- Policy amendments for state employee return to office
- Processing exception requests from appointing authorities
- Management of state-owned and leased real estate
Important: DAS administers policies for state employees only. Private sector employers are not under DAS jurisdiction.
2.3 Equal Employment Opportunity Commission (EEOC) – Cleveland Field Office
The EEOC Cleveland Field Office serves all of Ohio for federal employment discrimination matters.
Contact Information:
EEOC Cleveland Field Office
Anthony J. Celebrezze Federal Building
1240 E. 9th Street, Suite 3001
Cleveland, OH 44199
Telephone: 1-800-669-4000 (National Contact Center)
Local: (216) 522-2001 (for existing business with Cleveland office)
TTY: 1-800-669-6820
ASL Video Phone: 1-844-234-5122
Email: clevelandfieldoffice@eeoc.gov (for time-sensitive matters)
Attorney Submissions: clevatty@eeoc.gov
Website: https://www.eeoc.gov/field-office/cleveland
Public Portal: https://publicportal.eeoc.gov/
Office Hours: Monday – Friday, 9:00 AM to 4:00 PM (except Federal holidays)
Walk-in Hours: Monday, Tuesday, Thursday, Friday, 9:00 AM to 2:00 PM (appointments recommended)
Jurisdiction:
The Cleveland Field Office covers the entire state of Ohio for federal employment discrimination claims under:
- Title VII of the Civil Rights Act of 1964
- Americans with Disabilities Act (ADA)
- Age Discrimination in Employment Act (ADEA)
- Equal Pay Act (EPA)
- Genetic Information Nondiscrimination Act (GINA)
- Title II of the Civil Rights Act of 1991
Coverage: Employers with 15 or more employees (20 for age discrimination)
Filing Deadlines:
- 300 days from the discriminatory act in Ohio (due to worksharing agreement with OCRC)
- 180 days if no state agency has jurisdiction
Source: EEOC Cleveland Field Office
Available at: https://www.eeoc.gov/field-office/cleveland
OCRC-EEOC Worksharing Agreement:
Ohio has a worksharing agreement with the EEOC. Charges filed with either agency are considered dually filed, though typically only one agency investigates the matter.
Source: Ohio Civil Rights Commission and EEOC work sharing materials
2.4 Ohio Attorney General – Civil Rights Section
The Civil Rights Section of the Ohio Attorney General’s Office represents the Ohio Civil Rights Commission in litigation.
Contact Information:
Ohio Attorney General’s Office
Civil Rights Section
30 East Broad Street
Columbus, OH 43215
General Information: (614) 466-4986
Website: https://www.ohioattorneygeneral.gov/About-AG/Service-Divisions/Civil-Rights
Function:
- Litigation of discrimination cases on behalf of OCRC
- Representation of the Commission in administrative hearings
- Legal counsel to the Commission
Important Note: The Attorney General’s Office does NOT provide legal representation to individuals making discrimination allegations. Discrimination claims must be initiated through the Ohio Civil Rights Commission.
Source: Ohio Attorney General website
Available at: https://www.ohioattorneygeneral.gov/About-AG/Service-Divisions/Civil-Rights
Applicable Statutes - Compilation
3.1 Ohio Civil Rights Act – Chapter 4112
LAW: Ohio Civil Rights Act
REFERENCE: Ohio Revised Code Chapter 4112
ENACTED: 1959 (Ohio Civil Rights Commission established July 29, 1959)
LAST AMENDED: Various sections updated through 2023
FULL TEXT: https://codes.ohio.gov/ohio-revised-code/chapter-4112
ENFORCEMENT AGENCY: Ohio Civil Rights Commission
Key Protected Classes:
According to Ohio Revised Code § 4112.02, it is unlawful discriminatory practice:
“For any employer, because of the race, color, religion, sex, military status, national origin, disability, age, or ancestry of any person, to discharge without just cause, to refuse to hire, or otherwise to discriminate against that person with respect to hire, tenure, terms, conditions, or privileges of employment, or any matter directly or indirectly related to employment.”
Source: Ohio Revised Code § 4112.02(A)
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.02
Effective: April 6, 2023
Employer Coverage:
According to Ohio Revised Code § 4112.01(A)(2):
“‘Employer’ means the state, any political subdivision of the state, or a person employing four or more persons within the state, and any agent of the state, political subdivision, or person.”
Important: Ohio law covers employers with 4 or more employees, providing broader protection than federal law (which requires 15 employees for most protections).
Source: Ohio Revised Code § 4112.01
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.01
3.2 Federal Anti-Discrimination Laws
| Law | Reference | Protected Classes | Employer Size | Official Source |
|---|---|---|---|---|
| Americans with Disabilities Act (ADA) | 42 U.S.C. § 12101 et seq. | Disability | 15+ employees | https://www.ada.gov |
| Title VII of the Civil Rights Act | 42 U.S.C. § 2000e et seq. | Race, Color, Religion, Sex, National Origin | 15+ employees | https://www.eeoc.gov/statutes/title-vii-civil-rights-act-1964 |
| Age Discrimination in Employment Act (ADEA) | 29 U.S.C. § 621 et seq. | Age (40+) | 20+ employees | https://www.eeoc.gov/statutes/age-discrimination-employment-act-1967 |
| Equal Pay Act (EPA) | 29 U.S.C. § 206(d) | Sex (compensation) | All employers | https://www.eeoc.gov/statutes/equal-pay-act-1963 |
| Genetic Information Nondiscrimination Act (GINA) | 42 U.S.C. § 2000ff et seq. | Genetic Information | 15+ employees | https://www.eeoc.gov/statutes/genetic-information-nondiscrimination-act-2008 |
| Pregnancy Discrimination Act | 42 U.S.C. § 2000e(k) | Pregnancy | 15+ employees | https://www.eeoc.gov/statutes/pregnancy-discrimination-act-1978 |
Source: U.S. Equal Employment Opportunity Commission
Available at: https://www.eeoc.gov/laws/statutes
3.3 Key Statutory Provisions – Ohio Law
ANTI-RETALIATION PROTECTION
Ohio Revised Code § 4112.02(I) provides:
“For any person to discriminate in any manner against any other person because that person has opposed any unlawful discriminatory practice defined in this section or because that person has made a charge, testified, assisted, or participated in any manner in any investigation, proceeding, or hearing under sections 4112.01 to 4112.07 of the Revised Code.”
Source: Ohio Revised Code § 4112.02(I)
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.02
Effective: April 6, 2023
LIBERAL CONSTRUCTION
Ohio Revised Code § 4112.08 establishes:
“This chapter shall be construed liberally for the accomplishment of its purposes, and any law inconsistent with any provision of this chapter shall not apply.”
Source: Ohio Revised Code § 4112.08
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.08
Effective: April 15, 2021
AGE DISCRIMINATION
Ohio Revised Code § 4112.14 prohibits age discrimination against individuals aged 40 and over.
Source: Ohio Revised Code § 4112.14
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.14
DEFINITION OF DISABILITY
Ohio law follows the ADA Amendments Act of 2008 definition, providing broad protection for individuals with physical or mental impairments that substantially limit one or more major life activities.
Source: Ohio Revised Code § 4112.01 and ADA, 42 U.S.C. § 12102
3.4 Remedies and Enforcement
ADMINISTRATIVE REMEDY
Ohio Revised Code § 4112.051 establishes the process for filing charges with OCRC and obtaining right to sue notices.
Source: Ohio Revised Code § 4112.051
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.051
CIVIL ACTION
Ohio Revised Code § 4112.052 governs civil actions for employment discrimination.
Key provisions:
- Must file charge with OCRC before filing civil action (with exceptions)
- Must receive notice of right to sue or meet other statutory requirements
- Two-year statute of limitations from discriminatory act (with exceptions)
Source: Ohio Revised Code § 4112.052
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.052
Effective: Current through 2025
Reasonable Accommodations - Official Framework
4.1 Ohio Law Requirements
EMPLOYER SIZE THRESHOLD
Ohio law requires employers with 4 or more employees to provide reasonable accommodations, providing broader protection than federal ADA requirements (15 employees).
Source: Ohio Revised Code § 4112.01(A)(2)
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.01
DISABILITY DEFINITION
According to the Americans with Disabilities Act as adopted by Ohio law, an individual with a disability is a person who:
- Has a physical or mental impairment that substantially limits one or more major life activities
- Has a record of such an impairment
- Is regarded as having such an impairment
Major life activities include: caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, working, and the operation of major bodily functions.
Source: 42 U.S.C. § 12102 (ADA Amendments Act of 2008)
Available at: https://www.ada.gov
REASONABLE ACCOMMODATION REQUIREMENT
According to Ohio Revised Code Chapter 4112 and the ADA, employers must provide reasonable accommodations to qualified individuals with disabilities unless doing so would impose an undue hardship on the operation of the employer’s business.
A reasonable accommodation is any modification or adjustment to a job, work environment, or hiring process that enables a qualified individual with a disability to:
- Participate in the application process
- Perform essential functions of the job
- Enjoy benefits and privileges of employment equal to those enjoyed by employees without disabilities
Source: EEOC Enforcement Guidance on Reasonable Accommodation and Undue Hardship
Available at: https://www.eeoc.gov/laws/guidance/enforcement-guidance-reasonable-accommodation-and-undue-hardship-under-ada
4.2 Interactive Process
According to guidance published by Opportunities for Ohioans with Disabilities and the EEOC, the interactive process is a collaborative effort where the employer and employee engage in dialogue to:
- Clarify what the individual needs
- Identify the workplace barrier
- Determine effective reasonable accommodations
INTERACTIVE PROCESS STEPS:
STEP 1: Request for Accommodation
According to the EEOC:
“To request accommodation, a person may use ‘plain English’ and need not mention the ADA or use the phrase ‘reasonable accommodation.'”
An accommodation request can be made:
- Orally or in writing
- By the employee or their representative
- At any time (during hiring process, after hire, or when a barrier arises)
Source: EEOC Enforcement Guidance
Available at: https://www.eeoc.gov/laws/guidance/enforcement-guidance-reasonable-accommodation-and-undue-hardship-under-ada
STEP 2: Verification of Disability and Need
According to Opportunities for Ohioans with Disabilities:
“When you request a reasonable accommodation, the employer may ask you for some information about your disability to establish, or make sure, that you are a person with a disability protected by the law.”
Employers may request:
- Documentation of the disability
- Information about functional limitations
- How the disability affects job performance
- Why accommodation is needed
Important: Medical information must be kept confidential in separate files from personnel records.
Source: Opportunities for Ohioans with Disabilities
Document: “Navigating the Reasonable Accommodation Process”
Available at: https://ood.ohio.gov (Employer Resources)
STEP 3: Identifying Possible Accommodations
According to the interactive process guidance:
“The interactive process is a collaborative effort where the ADA Coordinator and individual seeking an accommodation engage in dialogue to clarify what the individual needs and identify potential reasonable accommodations.”
The employer should:
- Consult with the employee about their specific needs
- Review job descriptions and essential functions
- Consider multiple accommodation options
- Explore resources like the Job Accommodation Network
Source: Ohio Civil Rights Commission ADA Policy
Available at: https://dam.assets.ohio.gov/image/upload/v1719349915/civ.ohio.gov/ADA/Title_I_ADA_Reasonable_Accommodation_Policy_-_6.25.24.pdf
STEP 4: Implementation and Follow-up
According to published guidance:
“The reasonable accommodation process will not be considered completed until the employee and their supervisor have evaluated the effectiveness of the accommodation in performing essential job functions.”
Source: Ohio state agency ADA policies
4.3 Types of Reasonable Accommodations
According to the EEOC and Opportunities for Ohioans with Disabilities, reasonable accommodations may include:
Workplace Modifications:
- Modified work schedules or part-time schedules
- Telework or remote work arrangements
- Reassignment to a vacant position
- Modifications to workspace
- Accessible parking
Equipment and Technology:
- Assistive technology
- Screen readers or magnification software
- Ergonomic equipment
- Accessible computer stations
Policy Modifications:
- Modified break schedules
- Flexible leave policies
- Job restructuring (redistributing marginal functions)
- Modified training materials or methods
Leave as Accommodation:
- Extended leave beyond FMLA
- Intermittent leave
- Modified attendance policies
Communication Accommodations:
- Sign language interpreters
- Modified communication methods
- Written instructions
Source: Job Accommodation Network (JAN)
Available at: https://askjan.org
Operated by: U.S. Department of Labor
TELEWORK/REMOTE WORK AS ACCOMMODATION:
According to EEOC guidance, telework or remote work can be a form of reasonable accommodation. The EEOC has stated:
“Telework (also referred to as remote work) may be a reasonable accommodation if it enables an employee to perform the essential functions of the job without causing an undue hardship to the employer.”
Important considerations:
- Must be evaluated on case-by-case basis
- Employee must be able to perform essential functions remotely
- Employer may deny if it creates undue hardship
- Cannot be denied simply because other employees are required to work on-site
Source: EEOC, “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws”
Available at: https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws
4.4 Undue Hardship
Employers are not required to provide accommodations that would impose an undue hardship.
According to 42 U.S.C. § 12111(10), undue hardship means:
“An action requiring significant difficulty or expense, when considered in light of factors such as:
- Nature and cost of accommodation
- Overall financial resources of the facility
- Number of persons employed at the facility
- Effect on expenses and resources
- Impact on facility operations
- Overall size and resources of the covered entity
- Type of operation”
Source: Americans with Disabilities Act, 42 U.S.C. § 12111(10)
Available at: https://www.ada.gov
Important: Undue hardship is fact-specific and requires individualized assessment. Employers have burden of proving undue hardship.
4.5 Official Resources for Accommodations
Job Accommodation Network (JAN)
Website: https://askjan.org
Toll-Free: 1-800-526-7234
Function: Free consulting service providing information about job accommodations and ADA
Operated by: U.S. Department of Labor, Office of Disability Employment Policy
Opportunities for Ohioans with Disabilities (OOD)
Website: https://ood.ohio.gov
Phone: 1-800-282-4536
Function: State agency providing employment services and employer consultation on disability inclusion
ADA National Network
Website: https://adata.org
Toll-Free: 1-800-949-4232
Function: Information, guidance, and training on ADA
Official Complaint Process
5.1 Ohio Civil Rights Commission (OCRC) – State Agency Filing
FILING DEADLINE: 2 years from the date of the alleged discriminatory act
Source: Ohio Revised Code § 4112.051
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.051
HOW TO FILE:
1. Online Filing:
URL: https://civ.ohio.gov/how-to-file-a-charge/filing-a-charge
Process: Complete online intake questionnaire and file charge electronically
2. By Phone:
Toll-Free: 1-888-278-7101
Local (Columbus): (614) 466-2785
TTY: 1-800-750-0750 (English) / 1-888-269-0678 (Spanish)
Process: Call to schedule appointment to file charge
3. By Mail:
Address:
Ohio Civil Rights Commission
30 East Broad Street, 5th Floor
Columbus, OH 43215
Process: Request forms by phone or download from website, complete and mail
4. In Person:
Location: OCRC Central or Regional Offices (by appointment)
Appointment Required: Effective February 13, 2023
Schedule: Call 1-888-278-7101
OFFICIAL PROCESS (from OCRC):
Step 1: Filing the Charge
According to Ohio Revised Code § 4112.051:
“Any person claiming to be aggrieved by an unlawful discriminatory practice may file a charge with the commission. The charge shall be in writing and under oath or affirmation.”
The charge must include:
- Complainant’s name and contact information
- Respondent’s name and contact information
- Description of the alleged discriminatory practice
- Date(s) of the alleged discrimination
Step 2: Preliminary Investigation
According to OCRC materials:
“OCRC must complete a preliminary investigation of the charge’s merits within 100 days after filing.”
During the preliminary investigation:
- OCRC gathers information from both parties
- Parties may be offered mediation
- OCRC determines if there is probable cause
Step 3: Probable Cause Determination
If NO PROBABLE CAUSE: OCRC dismisses the charge and issues a notice of right to sue (allowing complainant to file civil lawsuit)
If PROBABLE CAUSE: OCRC attempts conciliation (settlement negotiations)
Step 4: Conciliation or Hearing
If conciliation successful: Case resolved through settlement agreement
If conciliation fails: OCRC issues formal complaint and schedules public hearing before Administrative Law Judge
Timeline: OCRC must issue finding within 1 year after charge is filed
Source: Ohio Revised Code § 4112.05
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.05
Step 5: Notice of Right to Sue
Complainant may request notice of right to sue:
- After 60 days from filing charge
- If OCRC has not issued finding of probable cause or no probable cause
Upon receipt of notice of right to sue, complainant may file civil action in court.
Source: Ohio Revised Code § 4112.051
CONTACT INFORMATION FOR FILING:
Ohio Civil Rights Commission
30 East Broad Street, 5th Floor
Columbus, OH 43215
Phone: (614) 466-2785
Toll-Free: 1-888-278-7101
TTY: 1-800-750-0750 (English) / 1-888-269-0678 (Spanish)
Email: PACE@civ.ohio.gov
Website: https://civ.ohio.gov
Hours: Monday – Friday, 8:00 AM to 5:00 PM
5.2 Equal Employment Opportunity Commission (EEOC) – Federal Agency Filing
FILING DEADLINE: 300 days from the discriminatory act in Ohio (due to worksharing agreement with OCRC)
Important: If no state agency has jurisdiction, deadline is 180 days
Source: EEOC regulations, 29 C.F.R. § 1601.13
DUAL FILING: Ohio has worksharing agreement with EEOC
According to EEOC materials:
“Charges filed with either the OCRC or EEOC are considered dually filed with both agencies, though typically only one agency investigates.”
Source: EEOC-OCRC worksharing agreement
HOW TO FILE WITH EEOC:
1. Online Portal:
URL: https://publicportal.eeoc.gov/
Process:
- Submit online inquiry
- Schedule intake appointment (phone, video, or in-person)
- Complete charge of discrimination
2. By Phone:
National: 1-800-669-4000
TTY: 1-800-669-6820
ASL Video Phone: 1-844-234-5122
Process: Call to initiate inquiry and schedule appointment
3. In Person (Cleveland Field Office):
Address:
Anthony J. Celebrezze Federal Building
1240 E. 9th Street, Suite 3001
Cleveland, OH 44199
Walk-in Hours: Monday, Tuesday, Thursday, Friday, 9:00 AM to 2:00 PM
Note: Appointments recommended; walk-ins seen on first-come, first-served basis
4. Attorney Filing:
Email: clevatty@eeoc.gov
Platform: EEOC E-File for Attorneys
Website: https://www.eeoc.gov
EEOC PROCESS:
Step 1: Intake/Assessment
- EEOC representative interviews charging party
- Assesses whether charge falls under EEOC jurisdiction
- Provides information about process and rights
Step 2: Charge Filing
- Formal charge filed under oath
- EEOC notifies employer (respondent)
Step 3: Mediation (Optional)
- Voluntary mediation offered
- Free and confidential
- If successful, case resolved
Step 4: Investigation
- EEOC investigates allegations
- Requests information from both parties
- May conduct interviews
Step 5: Determination
Cause Finding: EEOC finds reasonable cause to believe discrimination occurred; attempts conciliation
No Cause Finding: EEOC dismisses charge and issues Notice of Right to Sue
Step 6: Notice of Right to Sue
Issued when:
- EEOC completes investigation
- 180 days have passed since charge filed (upon request)
- EEOC determines it will not proceed
Step 7: Civil Action
Charging party has 90 days from receipt of Notice of Right to Sue to file lawsuit in federal court
Source: EEOC Charge Processing Procedures
Available at: https://www.eeoc.gov/filing-charge-discrimination
EEOC CLEVELAND FIELD OFFICE:
Address:
Anthony J. Celebrezze Federal Building
1240 E. 9th Street, Suite 3001
Cleveland, OH 44199
Phone: 1-800-669-4000 (National) / (216) 522-2001 (Local)
TTY: 1-800-669-6820
ASL Video Phone: 1-844-234-5122
Email: clevelandfieldoffice@eeoc.gov
Website: https://www.eeoc.gov/field-office/cleveland
Hours: Monday – Friday, 9:00 AM to 4:00 PM
5.3 Civil Lawsuit Options
OHIO COURT ACTION
According to Ohio Revised Code § 4112.052, individuals may file civil action in Ohio common pleas court if:
- Charge filed with OCRC within required timeframe, AND
- One of the following:
- Received notice of right to sue from OCRC
- Requested right to sue and OCRC failed to issue within 45 days
- OCRC found probable cause and complainant elected to proceed in court
Statute of Limitations: 2 years from discriminatory act (with exceptions)
Source: Ohio Revised Code § 4112.052
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.052
FEDERAL COURT ACTION
Under federal law, individuals may file lawsuit in U.S. District Court after:
- Filing charge with EEOC
- Receiving Notice of Right to Sue
Statute of Limitations: 90 days from receipt of Notice of Right to Sue
Source: Title VII, 42 U.S.C. § 2000e-5(f)(1)
Published Official Documents
6.1 Executive Order 2025-01D
DOCUMENT: Executive Order 2025-01D
PUBLISHED BY: Office of Governor Mike DeWine
DATE: February 4, 2025
SUMMARY: Requires state employees under Governor’s authority to return to physical office locations by March 17, 2025, with limited exceptions for field workers and situations where in-office work is not reasonable
LINK: https://governor.ohio.gov/media/executive-orders/executive-order-2025-01d
PDF: https://content.govdelivery.com/attachments/OHIOGOVERNOR/2025/02/04/file_attachments/3154036/Executive%20Order%202025-01D.pdf
FORMAT: PDF
PAGES: 2
6.2 Ohio Revised Code Chapter 4112
DOCUMENT: Ohio Civil Rights Act
PUBLISHED BY: Ohio General Assembly
DATE: Originally enacted 1959; continuously updated
SUMMARY: Comprehensive anti-discrimination law prohibiting discrimination in employment, housing, public accommodations, credit, and higher education on bases of race, color, religion, sex, military status, national origin, disability, age, and ancestry
LINK: https://codes.ohio.gov/ohio-revised-code/chapter-4112
FORMAT: HTML
LAST UPDATED: Various sections through 2023
6.3 Ohio Civil Rights Commission Materials
DOCUMENT: Fair Employment Poster
PUBLISHED BY: Ohio Civil Rights Commission
DATE: 2021
SUMMARY: Official workplace poster outlining employee rights under Ohio Civil Rights Act
LINK: https://civ.ohio.gov/static/Misc/FEP%20Poster%202021.pdf
FORMAT: PDF
DOCUMENT: ADA Title I Reasonable Accommodation Policy
PUBLISHED BY: Ohio Civil Rights Commission
DATE: June 25, 2024
SUMMARY: Official policy on reasonable accommodation process, interactive process, confidentiality, appeals
LINK: https://dam.assets.ohio.gov/image/upload/v1719349915/civ.ohio.gov/ADA/Title_I_ADA_Reasonable_Accommodation_Policy_-_6.25.24.pdf
FORMAT: PDF
DOCUMENT: How to File a Charge
PUBLISHED BY: Ohio Civil Rights Commission
DATE: Current
SUMMARY: Guide to filing discrimination charges with OCRC
LINK: https://civ.ohio.gov/how-to-file-a-charge/filing-a-charge
FORMAT: HTML
6.4 Opportunities for Ohioans with Disabilities Materials
DOCUMENT: “Navigating the Reasonable Accommodation Process”
PUBLISHED BY: Opportunities for Ohioans with Disabilities
DATE: April 13, 2022
SUMMARY: Learner’s guide on interactive process, requesting accommodations, and employer responsibilities
LINK: https://dam.assets.ohio.gov/image/upload/ood.ohio.gov/Literature/OOD%20Navigating%20the%20RA%20Process%20Learner’s%20Guide%20041322.pdf
FORMAT: PDF
DOCUMENT: “The Employers’ Reasonable Accommodation Handbook”
PUBLISHED BY: Opportunities for Ohioans with Disabilities
DATE: Current
SUMMARY: Comprehensive guide for employers on providing reasonable accommodations for various disability types
LINK: https://dam.assets.ohio.gov/image/upload/ood.ohio.gov/Literature/Employers’%20Reasonable%20Accommodation%20Handbook%20Learner’s%20Guide.pdf
FORMAT: PDF
6.5 EEOC Federal Guidance
DOCUMENT: “Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA”
PUBLISHED BY: U.S. Equal Employment Opportunity Commission
DATE: October 17, 2002 (continuously referenced)
SUMMARY: Comprehensive guidance on reasonable accommodation requirements, interactive process, and undue hardship standard
LINK: https://www.eeoc.gov/laws/guidance/enforcement-guidance-reasonable-accommodation-and-undue-hardship-under-ada
FORMAT: HTML
DOCUMENT: “What You Should Know About COVID-19 and the ADA”
PUBLISHED BY: U.S. Equal Employment Opportunity Commission
DATE: Updated periodically
SUMMARY: Guidance on ADA compliance including remote work as reasonable accommodation
LINK: https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws
FORMAT: HTML
6.6 No State-Issued Private Sector RTO Guidance
SEARCH CONDUCTED:
Ohio Department of Administrative Services:
Website: https://das.ohio.gov
Date: December 20, 2025
Search Terms: “return to office”, “remote work private sector”, “telework policy”
Result: No guidance for private sector employers identified; Executive Order 2025-01D applies only to state employees
Ohio Civil Rights Commission:
Website: https://civ.ohio.gov
Date: December 20, 2025
Search Terms: “return to office”, “remote work accommodation”
Result: No RTO-specific guidance; general reasonable accommodation guidance applies
Ohio Department of Commerce:
Website: https://com.ohio.gov
Date: December 20, 2025
Result: No RTO guidance for private employers
Conclusion: As of December 20, 2025, no Ohio state agencies have published specific guidance on return to office mandates for private sector employers. Private employers must comply with existing anti-discrimination laws and reasonable accommodation requirements under Ohio and federal law.
Absence of Private Sector RTO Legislation
Legislative Research Results
As of December 20, 2025, searches of the Ohio Legislature website reveal:
No specific statutes enacted governing return to office mandates for private sector employers.
Search conducted:
- Website: Ohio General Assembly – https://legislature.ohio.gov
- Date: December 20, 2025
- Search terms: “return to office”, “remote work mandate”, “telework requirements”, “workplace flexibility”, “hybrid work”
- Databases searched: Current bills, enacted legislation, Ohio Revised Code
Result: No relevant private sector legislation identified
Executive Order 2025-01D Scope:
Executive Order 2025-01D applies exclusively to:
- State agencies, boards, and commissions under the Governor’s authority
- Permanent state employees
The order explicitly does not apply to:
- Private sector employers
- Private sector employees
- Offices of elected officials not under Governor’s authority
- Independent state agencies
Source: Executive Order 2025-01D, Section 3
Available at: https://governor.ohio.gov/media/executive-orders/executive-order-2025-01d
General Employment Framework Applies to Private Employers:
Private sector employers in Ohio operate under:
- At-will employment: Ohio Revised Code (common law doctrine, no specific statute number)
- Anti-discrimination laws: Ohio Revised Code Chapter 4112
- Disability accommodation requirements: Ohio Revised Code § 4112.02 and ADA, 42 U.S.C. § 12101
- Anti-retaliation protections: Ohio Revised Code § 4112.02(I)
- Federal employment laws: Title VII, ADA, ADEA, FMLA
- Contract law: Express and implied employment contracts
- Collective bargaining agreements: Where applicable
Key Principle for Private Employers:
While private employers in Ohio may implement return to office policies at their discretion under at-will employment principles, they must:
- Comply with anti-discrimination laws – Cannot make RTO decisions based on protected characteristics
- Provide reasonable accommodations – Must engage in interactive process for disability-related accommodation requests
- Avoid retaliation – Cannot retaliate against employees who request accommodations or file discrimination complaints
- Honor contracts – Must comply with any express employment agreements or collective bargaining agreements
- Follow public policy – Cannot terminate in violation of recognized public policy
Source: Ohio employment law framework, Ohio Revised Code Chapter 4112, federal employment laws
Frequently Asked Questions - RTO mandate Ohio
What is Ohio’s return to office mandate?
Ohio’s return to office mandate refers to Executive Order 2025-01D, signed by Governor Mike DeWine on February 4, 2025, requiring state employees under the Governor’s authority to return to physical office locations by March 17, 2025.
Key details:
- Applies to state agencies, boards, and commissions under the Governor
- Affects approximately 15,400 state employees previously on remote or hybrid schedules
- Does not apply to private sector employers or employees
- Allows limited exceptions for field workers and situations where in-office work is not reasonable
- Effective date: March 17, 2025
Source: Executive Order 2025-01D
Available at: https://governor.ohio.gov/media/executive-orders/executive-order-2025-01d
Does Ohio’s RTO mandate apply to private employers?
No. Executive Order 2025-01D applies exclusively to state employees working for agencies, boards, and commissions under the Governor’s authority. Private sector employers are not covered by this executive order.
Private employers in Ohio operate under at-will employment principles and existing anti-discrimination laws. They may implement return to office policies but must:
- Comply with Ohio Civil Rights Act and federal anti-discrimination laws
- Provide reasonable accommodations for employees with disabilities
- Honor employment contracts and collective bargaining agreements
- Avoid retaliatory or discriminatory employment practices
Source: Executive Order 2025-01D text and Ohio employment law framework
Available at: https://governor.ohio.gov/media/executive-orders/executive-order-2025-01d
Can my employer force me back to the office in Ohio?
For state employees covered by Executive Order 2025-01D, yes, unless you qualify for an exception. Exceptions may be granted for field workers or employees for whom reasonable in-office employment is not possible.
For private sector employees, Ohio is an at-will employment state, meaning employers generally have discretion to set workplace policies, including requiring office attendance. However, employers must:
- Provide reasonable accommodations for disabilities
- Not discriminate based on protected characteristics
- Honor employment contracts
- Comply with collective bargaining agreements
If you have a disability that requires remote work as an accommodation, you should request reasonable accommodation through your employer’s process.
Source: Executive Order 2025-01D; Ohio at-will employment law; ADA requirements
What are my accommodation rights under Ohio law?
Under Ohio Revised Code Chapter 4112 and the Americans with Disabilities Act (ADA), employees with disabilities have the right to request reasonable accommodations.
Key rights:
- Request accommodations at any time (hiring, during employment, or when barriers arise)
- Engage in interactive process with employer
- Receive accommodations unless they create undue hardship
- Keep medical information confidential
- Protection from retaliation for requesting accommodations
Coverage:
- Ohio law: Employers with 4 or more employees
- Federal ADA: Employers with 15 or more employees
Reasonable accommodations may include modified schedules, telework, assistive technology, modified duties, or leave arrangements.
Source: Ohio Revised Code § 4112.02; ADA, 42 U.S.C. § 12101
Available at: https://codes.ohio.gov/ohio-revised-code/section-4112.02
How do I file a discrimination complaint in Ohio?
With Ohio Civil Rights Commission (OCRC):
Deadline: 2 years from discriminatory act
Filing methods:
- Online: https://civ.ohio.gov/how-to-file-a-charge/filing-a-charge
- Phone: 1-888-278-7101
- In person: By appointment at regional offices
- Mail: OCRC, 30 E. Broad St., 5th Floor, Columbus, OH 43215
Process:
- File charge (in writing, under oath)
- OCRC investigates (100-day preliminary investigation)
- Probable cause determination
- Conciliation or hearing if probable cause found
- Right to sue notice available after 60 days
With EEOC:
Deadline: 300 days from discriminatory act in Ohio
Filing methods:
- Online portal: https://publicportal.eeoc.gov/
- Phone: 1-800-669-4000
- In person: Cleveland Field Office (by appointment or walk-in)
Dual filing: Charges filed with either agency are typically cross-filed with the other.
Contact:
- OCRC: (614) 466-2785 / 1-888-278-7101
- EEOC: 1-800-669-4000
Source: Ohio Revised Code § 4112.051; EEOC regulations
Can I request remote work as a reasonable accommodation?
Yes. According to EEOC guidance, telework or remote work may be a reasonable accommodation if it enables an employee with a disability to perform essential job functions without causing undue hardship to the employer.
Request process:
- Inform employer you need accommodation due to disability
- Explain why remote work is needed
- Engage in interactive process
- Provide medical documentation if requested
- Work with employer to identify effective accommodation
Important considerations:
- Evaluated case-by-case basis
- Must be able to perform essential functions remotely
- Employer may deny if it creates undue hardship
- Cannot be denied simply because other employees work on-site
- For state employees under Executive Order 2025-01D, exceptions may be granted through appointing authority
Source: EEOC, “What You Should Know About COVID-19 and the ADA”
Available at: https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws
What is Ohio’s Civil Rights Act?
Ohio Revised Code Chapter 4112, known as the Ohio Civil Rights Act, is Ohio’s comprehensive anti-discrimination law enacted in 1959.
Protected classes:
- Race
- Color
- Religion
- Sex (including pregnancy)
- National origin
- Disability
- Age (40 and over)
- Ancestry
- Military status
- Familial status (housing)
Coverage areas:
- Employment
- Housing
- Public accommodations
- Credit
- Disability in higher education
Employer coverage: 4 or more employees (broader than federal law)
Enforcement agency: Ohio Civil Rights Commission
Source: Ohio Revised Code Chapter 4112
Available at: https://codes.ohio.gov/ohio-revised-code/chapter-4112
Where do I file an EEOC complaint in Ohio?
EEOC Cleveland Field Office serves all of Ohio.
Address:
Anthony J. Celebrezze Federal Building
1240 E. 9th Street, Suite 3001
Cleveland, OH 44199
Contact:
- National: 1-800-669-4000
- Local: (216) 522-2001
- TTY: 1-800-669-6820
- ASL Video Phone: 1-844-234-5122
- Email: clevelandfieldoffice@eeoc.gov
Hours: Monday – Friday, 9:00 AM to 4:00 PM
Walk-ins: Monday, Tuesday, Thursday, Friday, 9:00 AM to 2:00 PM (appointments recommended)
Online filing: https://publicportal.eeoc.gov/
Deadline: 300 days from discriminatory act in Ohio (180 days if no state agency jurisdiction)
Source: EEOC Cleveland Field Office
Available at: https://www.eeoc.gov/field-office/cleveland
What is at-will employment in Ohio?
At-will employment means either the employer or employee can terminate the employment relationship at any time, for any reason not prohibited by law, with or without notice.
According to the Ohio Legislative Service Commission:
“Ohio is an employment-at-will state, which means that, in the absence of a written employment agreement or a collective bargaining agreement, either the employer or the employee can terminate employment for any reason which is not contrary to law.”
Exceptions to at-will employment:
- Express or implied employment contracts
- Collective bargaining agreements
- Public policy violations (e.g., termination for jury duty)
- Statutory protections (discrimination, retaliation)
- Promissory estoppel
- Covenant of good faith and fair dealing (limited in Ohio)
How it affects RTO:
Under at-will employment, employers generally have discretion to require office attendance. However, they cannot:
- Discriminate based on protected characteristics
- Retaliate against employees who request accommodations
- Violate employment contracts
- Terminate in violation of public policy
Source: Ohio common law; Ohio Legislative Service Commission
Available at: https://www.lsc.ohio.gov/assets/organizations/legislative-service-commission/files/employment-at-will-and-wrongful-discharge-in-ohio-10014256.pdf