Pittsburgh, PA

Employment and Labor Alert

(by Cella Iovino and Katerina Vassil)

Over half of the states in the U.S. have enacted legislation to prohibit hair-based discrimination, and Pennsylvania has now followed suit. The Creating a Respectful and Open World for Natural Hair (CROWN) Act, signed into law on November 25, 2025, goes into effect on January 24, 2026. This state-wide measure follows CROWN Act ordinances passed by the Allegheny County and Pittsburgh City Councils in 2020 offering local protections, but Pennsylvania’s new law has several unique nuances.

The purpose of the CROWN Act is to address longstanding biases where natural hair and protective styles were deemed to be unprofessional or inappropriate, resulting in racial or religious discrimination. To target this bias, the CROWN Act amends the Pennsylvania Human Relations Act (PHRA) to include protection against discrimination based on hair texture, type, and styles commonly or historically associated with one’s race or religion. Specifically, “race” under the PHRA is expanded to include “traits historically associated with the individual’s race, including hair texture and protective hairstyle.” The CROWN Act defines “protective hairstyle” under the PHRA to include locs, braids, twists, coils, Bantu knots, afros, and extensions, though it is not limited to these examples. The CROWN Act also adds to the PHRA’s definition of “religious creed” to now include “head coverings and hairstyles historically associated with religious creeds.”

Unlike the Allegheny County and Pittsburgh ordinances, the Pennsylvania CROWN Act includes a strict four-part test that employers must meet in order to adopt rules, policies, or grooming standards that impact traits, hairstyles, and head coverings historically associated with one’s race or religion as a “justified bona fide occupational requirement.” To comply with the law, an employer’s policy that impacts such hair textures or protective hairstyles must be: (1) necessary to protect the health or safety of an employee or other materially protected person; (2) adopted for non-discriminatory reasons; (3) specifically tailored to the applicable position and activity; and (4) applied equally to individuals whose positions fall under that position and category.

The CROWN Act applies to employers, labor organizations, and employment agencies with four or more employees in Pennsylvania. Employers should review policies and procedures related to dress code, grooming, and appearance prior to the CROWN Act’s effective date, and update these policies and procedures as necessary to be compliant. Similarly, employers should review and update anti-harassment policies to reflect that discrimination based on natural hair, protective hairstyles, or religious head coverings is prohibited under the PHRA. Employers should ensure that managers and supervisors understand the scope of CROWN Act protections, and all policy changes should be shared with managers, supervisors, and employees alike.

If you have any questions about the CROWN Act, please contact Francesca C. Iovino at (412) 394-6460 or fiovino@babstcalland.com or Katerina P. Vassil at (412) 394-6428 or kvassil@babstcalland.com.

 

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