For most employers with employees working in Pennsylvania, the new CROWN Act should not have a significant impact on operations.

On November 25, 2025, Pennsylvania Governor Josh Shapiro signed into law the Create a Respectful and Open Workspace for Natural Hair Act, known as the CROWN Act, which amends the Pennsylvania Human Relations Act (PHRA) to clarify that the term “race” includes traits associated with race, such as hair texture and protective hairstyles. Joining 28 states and counting, in enacting the CROWN Act, Pennsylvania codifies into law the concept that hairstyles and head coverings associated with an employee’s race or religious creed can be protected characteristics.

Pennsylvania’s CROWN Act

The PHRA has long prohibited employment discrimination based on an employee’s race or religious creed (among other protected characteristics). In 2023, as part of a nationwide trend, the Pennsylvania Human Relations Commission (PHRC) passed regulations stating that race includes “traits associated with race” and such traits include “hair texture and protective hairstyles, such as braids, locks and twists.” Additional guidance from the PHRC explained that examples of actions that could violate the PHRA included “firing a person because of their hairstyle” and “creating company policies requiring employees to alter their hair outside of safety codes.”

Two years later, the Pennsylvania Legislature has followed suit. The CROWN Act overwhelmingly passed the state Senate with nearly unanimous bipartisan support on November 19, 2025. It had previously sailed through the state House back in March 2025, also with nearly unanimous bipartisan passage. The amendment officially goes into effect January 24, 2026 [60 days from the date of the governor’s signature].

While Pennsylvania’s CROWN Act is similar to that of other states, it is not identical. Once in effect, the CROWN Act will amend the PHRA as follows:

• The term “race” will include “traits historically associated with the individual's race, including hair texture and protective hairstyles.”
• The term "protective hairstyle" will include, but not be limited to, such hairstyles as locs, braids, twists, coils, Bantu knots, afros and extensions.
• The term "religious creed" will include head coverings and hairstyles historically associated with religious creeds.
• An employer will not be prohibited from adopting and enforcing an otherwise valid workplace health and safety rule or policy or other rule or policy justified as a bona fide occupational qualification, provided the employer demonstrates all of the following, if the rule or policy impacts traits historically associated with the individual's race or head coverings and hairstyles historically associated with the individual's religious creed:
  • Without the adoption of the rule or policy, the health or safety of an employee or other materially connected person may be impaired.
  • The rule or policy is adopted for nondiscriminatory reasons.
  • The rule or policy is specifically tailored to the applicable position and activity.
  • The rule or policy is applied equally to individuals whose positions fall under the applicable position and activity.
• Similarly, an employer will not be prohibited from adopting and enforcing an otherwise valid workplace policy to prevent a hostile work environment, provided the policy is adopted for nondiscriminatory reasons and is applied equally.

Regarding the amendments about religious protections, the CROWN Act does not modify the definition of “religious creed” expressly, but specifies that hairstyles and head coverings historically associated with religious creed are covered by the PHRA.

How This Affects Employers

For most employers with employees working in Pennsylvania, the new CROWN Act should not have a significant impact on operations. As discussed above, the PHRC implemented regulations two years ago that provide protections for hair texture and hair styles associated with race. While those regulations did not specifically address hair styles and head coverings associated with an employee’s religious creed, the PHRA has been interpreted to protect such expressions of faith.

Similarly, the EEOC has published guidance advising that unlawful discrimination includes traits or characteristics linked to an individual’s race, such as hair textures and hairstyles commonly associated with specific racial groups. While federal law in this area has continued to evolve, courts have found that race-based discrimination can include discrimination based on how a person wears their hair.

That said, Pennsylvania’s CROWN Act, like similar legislation passed in other states and cities, does not automatically protect all hairstyles generally. Rather, there must be a connection between the hair texture, hair style or head covering that is associated with the employee’s race and/or religious creed.

Further, Pennsylvania law is also clear that employers may still enforce rules relating to safety, so long as such rules meet the four-part test set forth in the statute. For example, the CROWN Act would not prohibit an employer from requiring that all employees wear a correctly fitted helmet in an active construction site, even though it could affect an employee’s ability to wear certain hairstyles that may otherwise be protected. However, employers must also remember that an employee may still be entitled to the consideration of a reasonable accommodation for a religious belief, practice or observance. More specifically, if an employee requests a religious accommodation, the employer should follow its process for handling such accommodation requests and not rely on compliance with the four state factors to summarily dismiss the accommodation request as unreasonable and/or imposing an undue hardship on the company.

Finally, employers should note that the scope of activities prohibited by this amendment to the PHRA could include comments that were well-intentioned—for example, a supervisor who believes they are providing informal mentoring and guidance about a subordinate employee’s hair. It will not matter if the supervisor is of the same sex, race or religious creed as the employee; remarks that come off as disparaging or even disciplinary in nature carry increased risk.

Thus, it will be important that when an employer conducts EEO trainings, such trainings cover protections for religion- or race-related hair and head coverings. Employers should also remind managers in any antidiscrimination trainings that it is unlawful to discriminate generally based on attributes associated to race or creed (and other protected characteristics) and that customer preference is not a defense to such discrimination.

For More Information

If you have any questions about this Alert, please contact Jonathan A. Segal, Linda B. Hollinshead, Elizabeth Mincer, any of the attorneys in our Employment, Labor, Benefits and Immigration Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.