
Reasonable Accommodation and Modification Requests in California Rentals
Under California's fair housing regulations, a person with a disability may ask a housing provider for a reasonable accommodation (a change in a rule, policy, practice or service) or a reasonable modification (a physical change to the premises), at any time and in any form (2 CCR § 12176). If a request cannot be granted right away, the provider must engage in a timely, good-faith interactive process (2 CCR § 12177), and may ask only for limited information (2 CCR § 12178). Refusing a reasonable accommodation or modification is disability discrimination under both state and federal law (Gov. Code § 12927(c)(1); 42 U.S.C. § 3604(f)(3)).
The short version
- A request can be oral or written, made by the person, a family member or a representative, and need not use the words "reasonable accommodation" (§ 12176(f)).
- A provider may ask for a form but may not refuse a request because the form was not used (§ 12176(f)(5)).
- If the disability and the need are obvious or already known, no further information may be requested (§ 12178).
- Never ask for a diagnosis, medical records or the severity of a disability (§ 12178(e)).
- No fees or extra deposits to process or grant a request, except as § 12181 allows (§ 12180(a)(1)).
- In an ordinary private rental, the tenant pays for a physical modification; the owner may, where reasonable, require interior restoration at the end (Gov. Code § 12927(c)(1); 2 CCR § 12181).
Accommodation or modification?
| Reasonable accommodation | Reasonable modification | |
|---|---|---|
| What it is | "An exception, change, or adjustment in rules, policies, practices, or services" (§ 12176(a)) | "A change, alteration or addition to the physical premises" (§ 12176(b)) |
| Examples from the regulations | A tenant who receives disability benefits on the 6th asking to pay rent on the 6th (§ 12176(f)(8)); allowing a co-signer when disability limits income (§ 12176(f)(7)) | Installing a grab bar, for which an informal oral description is reasonable (§ 12181(c)) |
| Who pays | No fee or extra deposit may be charged to process or grant it (§ 12180(a)(1)) | The tenant, in an ordinary private rental (Gov. § 12927(c)(1); §§ 12179(c)(1), 12181(h)) |
Assistance animals have their own rules (they are not pets, and no pet fee, pet rent or extra deposit may be charged for them) on the pets and assistance animals page.
Handling a request, step by step
- Recognize the request. Any statement that a person needs a change because of a disability is a request, whether it comes in an email, a phone call, an application note or a conversation during an eviction case (§ 12176(f)(2) to (3), (8)).
- Acknowledge it in writing and note the date. There is no fixed response deadline in § 12177, but requests "must be promptly considered", and no response within a reasonable time "may constitute a denial" (§ 12177(d) to (e)).
- Decide whether you need anything more. If the request already gives reliable information about the disability and the need, or both are obvious or known, ask nothing further (§ 12178(a) to (b)).
- If you need information, ask only what is allowed (see the table below), and give a reasonable chance to provide it. You may not deny for lack of information without first asking for it (§ 12177(b)).
- Evaluate the request against the limited grounds for refusal.
- If you cannot grant it as asked, talk about alternatives. Discuss equally effective alternatives, give the person's preferences "significant weight", and grant an alternative that is effective and cannot lawfully be denied (§ 12177(c)).
- Respond in writing, with the decision and any conditions.
- Keep it confidential. Disability information, the request and any verification must be kept confidential and shared only with people directly involved in the decision or its implementation, or as the regulation otherwise allows (§ 12176(e)(1)).
What you may and may not ask
| Situation | What a provider may ask for |
|---|---|
| Disability and need are both obvious or already known | Nothing more (§ 12178(b)) |
| Disability is obvious, need is not | Only information describing the accommodation and showing how it relates to the disability (§ 12178(c)) |
| Disability is not obvious | Only what is necessary to establish a disability, a description of the accommodation, and the relationship between the two (§ 12178(d)) |
| Never | Diagnosis or medical condition, severity of the disability, medical records, medical history, or unrelated conditions (§ 12178(e)) |
Proof of disability is usually self-certification, such as proof of disability benefits or "a credible statement by the individual" (§ 12178(f)). It may also come from a reliable third party, such as a medical professional, health care provider, peer support group, service agency or caregiving relative (§ 12178(g)).
When a request can be refused
The grounds are narrow. Any request may be denied if the person does not have a disability or there is no disability-related need for it (§ 12179(a)). An accommodation may also be refused only if it would be an undue financial and administrative burden, a fundamental alteration, a direct threat to others' health or safety, or cause substantial physical damage to others' property (§ 12176(c)). Direct-threat and property-damage denials must rest on "an individualized assessment that relies on objective evidence, not on mere speculation or stereotype" (§ 12179(b)(3)). Undue burden and fundamental alteration do not apply where the need comes from the owner's failure to maintain the property as the law requires (§ 12179(d)). A denial may not rest on "fears or prejudices" or on the idea that other tenants might find it unfair (§ 12179(f)).
Rules specific to modifications
- The owner may ask for a reasonable description and assurances of workmanlike work and any permits, but may not require a particular contractor, liability waivers or insurance (§ 12181(c), (f)).
- The owner may require restoration of the interior to its prior condition, reasonable wear and tear excepted, only where reasonable, and never of exterior or common-area changes (§ 12181(a)). If a change does not affect the owner's or the next tenant's use, restoration generally cannot be required (§ 12179(c)(4)).
- The owner may not raise the customary security deposit, and may not automatically require escrow. Where needed to secure restoration, the parties may negotiate payments into an interest-bearing escrow account over a reasonable period, not exceeding the restoration cost, with interest going to the tenant (§ 12181(b); Civil Code § 54.1(b)(3)(A)).
- The tenant maintains a modification used only by their household (§ 12181(i)). If the owner wants costlier materials, the owner pays the difference (§ 12181(l)).
For owners
Write a short procedure: who receives requests, how they are logged, and who decides. You may offer an optional form, but accept requests in any form. Train anyone who answers the phone to recognize a request. Apply your written rental criteria consistently, and remember that a request can arise during a lease enforcement process; see handling lease violations. The broader rules are on the fair housing and source of income page.
For renters
You can ask at any time, in any form, and you do not need to use special words. Explain what you need and how it relates to your disability. You do not have to share your diagnosis or medical records. If the landlord needs more information, the request should say so specifically. Keep a copy of your request and the response. A physical modification is usually at your expense in a private rental, so discuss the scope and any restoration before work begins.
Local rules
Some California cities add rules on top of state law, such as local just-cause, relocation or rental registration requirements, so check your city's code. Coronado has no local rent-control or just-cause ordinance as of October 2026 (based on a review of its code's contents). Fair housing rules apply statewide.
Frequently asked questions
Does a reasonable accommodation request have to be in writing?
No. Under 2 CCR § 12176(f), a request may be oral or written, need not be made in a particular way or at a particular time, and does not need the words "reasonable accommodation". A provider may suggest a form but may not refuse a request because it was not used.
How long does a landlord have to respond to an accommodation request?
The regulations set no fixed number of days. Requests "must be promptly considered" case by case, and undue delay or no response within a reasonable time "may constitute a denial" (2 CCR § 12177(d) to (e)).
Can a landlord ask for a doctor's note?
Only in limited cases. If the disability or the need is not obvious, the provider may ask for information needed to establish the disability and the connection to the request, often satisfied by self-certification or a reliable third party (§ 12178). The provider may not ask for a diagnosis, medical records or the severity of the disability.
Can a landlord charge a fee or extra deposit for an accommodation?
No. It is unlawful to charge a fee or require an additional deposit as a condition of receiving, processing or granting a reasonable accommodation or modification, except as set forth in § 12181, such as a negotiated restoration escrow for a modification (2 CCR § 12180(a)(1)).
Who pays for a wheelchair ramp or grab bar in a rental?
In an ordinary private rental, the tenant pays for a reasonable modification (Gov. Code § 12927(c)(1); Civil Code § 54.1(b)(3)(A)). The owner may require interior restoration where reasonable, but not of exterior or common-area changes, and may not raise the security deposit because of the modification.
Can a tenant ask for an accommodation during an eviction?
Yes. Under § 12176(f)(8), a request may come at any point in the eviction process, and failure to accommodate may be raised as an affirmative defense in an unlawful detainer case.
This is general information, not legal advice. Laws change; confirm the current text and your situation with a California attorney.
McKee Properties manages rentals from its Coronado office; contact us with questions about your property.
Sources
- 2 CCR § 12176 (opens in a new tab)
- 2 CCR § 12177 (opens in a new tab)
- 2 CCR § 12178 (opens in a new tab)
- 2 CCR § 12179 (opens in a new tab)
- 2 CCR § 12180 (opens in a new tab)
- 2 CCR § 12181 (opens in a new tab)
- 2 CCR § 12185 (opens in a new tab)
- Government Code § 12927 (opens in a new tab)
- Government Code § 12955 (opens in a new tab)
- Civil Code § 54.1 (opens in a new tab)
- 42 U.S.C. § 3604 (opens in a new tab)
Verified October 19, 2026.
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