The Department of Housing and Urban Development told fair housing officials to exclude emotional support animals and tighten the definition of a qualified service animal, a move that could force thousands of disabled tenants and their animals out of housing. The memo, effective immediately, frames emotional support animals as a loophole used to circumvent landlord pet policies.

Under the Fair Housing Act, disabled tenants could previously request that no-pets restrictions be waived. The first Trump administration issued guidance protecting emotional support animals, but HUD now asserts that an entire industry has emerged to convert pets into emotional support animals. Requests to waive pet policies for untrained emotional support animals are no longer considered reasonable.

Erik Heins, a former HUD fair housing enforcement lawyer, said the policy could dismiss or shelve thousands of disability accommodation appeals. Veterans relying on emotional support animals for PTSD face particular risk. Landlords enforcing no-pets policies now face pressure to justify exclusions, with the memo creating friction between tenant rights and housing business operations.