Tennessee: Civil Rights Enforcement Restructured
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APPLIES TO All Employers with Employees in TN |
EFFECTIVE July 1, 2025 |
QUESTIONS? Contact HR On-Call |
Quick Look
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Discussion
In a significant shift for civil rights enforcement in Tennessee, HB 910/SB 861 dissolved the Tennessee Human Rights Commission (THRC) and transferred its enforcement duties to two separate agencies:
- The Division of Civil Rights Enforcement (CRED) within the state’s Attorney General’s Office now handles enforcement of the Tennessee Human Rights Act (THRA) and Tennessee Disability Act (TDA) for private-sector employers.
- The Tennessee Department of Human Resources (DOHR) is now responsible for ensuring state agencies comply with Title VI of the Civil Rights Act.
Effective July 1, 2025, employment discrimination complaints must be filed with CRED instead of the THRC, with a filing deadline of 180 days from the alleged incident. It is not yet confirmed whether CRED will enter into a work-sharing agreement with the EEOC, which would allow for dual filing and extend the EEOC filing deadline to 300 days.
The state Attorney General must appoint a Director of CRED, who will develop new procedures for filing, investigating, and resolving complaints under state law. It remains to be seen how CRED’s approach to enforcement may differ from that of the THRC.
Action Items
- Update complaint policies and procedures to reflect entity transitions.
- Have appropriate personnel trained on how to handle employee complaints.
- Monitor future developments between CRED and EEOC.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2025 ManagEase