Washington - Spokane, Washington Restricts Address Use in Hiring Process

Spokane, Washington has passed Ordinance C36666 (the Ordinance), which adds restrictions on how employers use an applicant’s address in the hiring process. The Ordinance takes effect on May 25, 2025.

The details

The Ordinance provides the following definitions:

• Homelessness is defined as not having a fixed or regular residence, including being homeless or unhoused, living on the streets, in a shelter, or in a temporary residence;
  
  
• Housing status is defined as the question as to whether a specific individual is experiencing homelessness; and
  
  
• Otherwise qualified means that an applicant meets the basic criteria for the position as set out in the job advertisement or job description without taking into account housing status or the existence or absence of a criminal conviction or arrest record.
  
  

Under the Ordinance, an employer cannot:

• Include a question in an application, or inquire orally or in writing, about housing status.  An employer may include an opportunity for an applicant to provide a mailing address or other means of contact as part of the application process.
  
  
• Require an applicant to provide an address or residence history until after granting a provisional offer of employment.
  
  
• Reject or disqualify an applicant solely because the individual does not have a fixed or regular residence; is homeless or unhoused; or lives on the street, in a shelter, or in a temporary residence.
  
  

Exceptions

The Ordinance does not:

• Cover an individual whose housing status has a bona fide and legitimate relation to the primary duties of the job, where rejecting or disqualifying the individual would also violate state or federal employment laws or regulations;
  
  
• Require an employer to provide accommodations or job modifications to facilitate the employment (or continued employment) of an individual experiencing homelessness; or
  
  
• Prohibit an employer from declining to hire an applicant experiencing homelessness or from terminating the employment of an employee experiencing homelessness, if the termination or refusal to hire is not solely based on housing status.
  
  

Next steps

Covered employers should review and update their hiring and notice policies and procedures and train supervisors on the law by May 25, 2025.