HUD now charges only trained-animal cases — but Connecticut boards answer to CHRO too
HUD now charges only trained-animal cases — but Connecticut boards answer to CHRO too
2026-09-09 · Connecticut · Regulation
The federal guidance Connecticut boards used to process assistance-animal requests has been withdrawn, and federal enforcement has been narrowed to animals trained to perform disability-related work. Neither change binds Connecticut's own fair housing enforcement.1
A Connecticut association that reads the federal shift as permission to deny emotional support animals is exposed on two fronts it has not accounted for.
What HUD withdrew
On September 17, 2025 HUD's Office of Fair Housing and Equal Opportunity issued a notice withdrawing nine guidance documents, effective on receipt. Two of them are the ones every community association in the country had been working from:
FHEO Notice 2013-01, on service animals and assistance animals in housing, and FHEO 2020-01, “Assessing a Person's Request to Have an Animal as a Reasonable Accommodation Under the Fair Housing Act.”1
The notice states the withdrawn guidance “should not be enforced or otherwise relied upon by the Department or stakeholders while this review is ongoing,” and that the documents “have been removed from the HUD.gov website and should not be relied upon by internal or external parties.”
The notice is addressed to FHEO, to Fair Housing Assistance Program agencies — which includes Connecticut's Commission on Human Rights and Opportunities — and to Fair Housing Initiatives Program grantees.
What HUD then did to enforcement
On May 22, 2026 the Assistant Secretary for Fair Housing and Equal Opportunity issued enforcement guidance to FHEO staff. Its operative sentence:
“Effective immediately, for complaints related to animal-related reasonable accommodations, FHEO will find reasonable cause and recommend charges only for those cases involving animals trained to provide disability-related assistance.”2
It adopts the ADA trained-service-animal standard, under which “the provision of emotional support, well-being, comfort, or companionship do not constitute work or tasks,” notes that over 20% of FHEO's fair housing complaints involve untrained emotional support animals, and announces an intention to conduct notice-and-comment rulemaking.
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Related Connecticut HOA Topics
- Notice of the Withdrawal of FHEO Guidance Documents, U.S. Department of Housing and Urban Development (September 17, 2025) ↩
- Enforcement Guidance — Assessing Requests for the Use of an Animal as a Reasonable Accommodation Under the Fair Housing Act, HUD (May 22, 2026) ↩
- Housing Discrimination Unit, Connecticut Commission on Human Rights and Opportunities ↩
- Commission on Human Rights and Opportunities ex rel. Pizzoferrato v. Mansions, LLC, SC 21111, 354 Conn. 273 (March 31, 2026) ↩
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