In both the United States and Canada, the concept of reasonable accommodation first emerged in equality law as a means of handling religious diversity. It was then applied to other grounds of discrimination, most notably disability. In the European Union, the evolution of antidiscrimination law is following a different path: a duty of reasonable accommodation was for the first time established by the 2000 Employment Equality Directive (or Directive 2000/78/EC) but only with respect to disability. Nonetheless, the question whether a right to reasonable accommodation can be derived from the prohibition of discrimination based on religion laid down by the same Directive, or, alternatively, whether such right should be recognized in future European legislation is becoming increasingly salient.

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 Emmanuelle Bribosia is a Professor at the Law Faculty of the Université libre de Bruxelles (ULB) and the Director of the Centre for European Law.  Isabelle Rorive is a Professor at the Law Faculty of the Université libre de Bruxelles (ULB) and the Director of the Perelman Centre for Legal Philosophy.  This research has been funded by the Interuniversity Attraction Poles Programme (IUAP), initiated by the Belgian Science Policy Office (BELSPO). More particularly, this paper has been written in the framework of the IUAP's project The Global Challenge of Human Rights Integration: Towards a Users ' Perspective (2012' Perspective ( -2017, . The authors are much indebted to all members of the Equality Law Clinic whose dedication and enthusiasm have been a source of inspiration. They also thank the participants in the expert meeting on 'Fragmentation and Integration in Human Rights Law: Users' Perspectives' held on 1 June 2017 at the European University Institute (Florence) as well as the participants at the annual a conference of the Berkeley comparative anti-discrimination study group organised at Trinity College Dublin on 14 June 2017, for their useful comments on a preliminary version of this paper and, in particular, Shreia Attrey for her constructive contribution as a discussant. Sara Aguirre also made very valuable comments. Finally, the authors warmly thank Eimear O'Neill for the precious editing work. 1 See, for instance, the April 2015 cover of Vanity Fair where the 1976 Olympic decathlon champion, Bruce Jenner, father and stepfather to a family of reality TV stars, came out as Caitlyn. For another example, see the four-page spread in Vogue US in April 2015 dedicated to Andreja Pejic (born Andrej), a famous model and the first trans model this fashion magazine ever featured. Since then, other examples have been on the rise. In February 2017, the cover of Vogue France was entitled "La beauté transgenre" and for the first time, the French magazine featured a trans model, Valentina Sampaio. 2 See, for instance, the Netflix TV series Orange is the New Black, for which in 2014, Laverne Cox became the first openly trans person to be nominated for a Emmy Award in the acting category. See also the transgender-focused US TV series, Transparent.3 Robin Hammond photographed 80 nine-year-olds in eight countries around the world for the National Geographic cover story in January 2017. He looked for different kinds of diversity: geographic, ethnic, socio-economic. According to the editor-in-chief, Susan Goldberg, the portrait of A., 'strong and proud … summed up the concept of "Gender Revolution"' accessed 3 July 2017. 4 The Sylvia Rivera Law Project (SRLP) is a collective organisation that works to guarantee that all people are free to determine their gender identity and expression, regardless of income or race, and without facing harassment, discrimination, or violence, accessed 3...

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