By Janet Epp-Buckingham,
Most of us spend a considerable portion of our lives working. That is why workplaces should be places of dignity and equal participation—places where people can earn a living without fear of discrimination or hostility because of their faith.
This is especially important for those whose religious convictions are expressed not only in belief, but in practice—through clothing, symbols, and visible signs. Yet across parts of Europe and beyond, governments have increasingly adopted restrictions that treat religious expression at work as a problem to be managed rather than a human right to be protected.
In many contexts, employers are moving in the opposite direction. The Religious Freedom & Business Foundation, together with leaders such as Brian Grim, has promoted the idea that employees should be able to “bring their whole selves to work.” That principle asks businesses to accommodate religious practices and to foster cultures where faith is not socially punished.
But what needs to be addressed is different: not private acceptance, but government restrictions on religion in the workplace—particularly restrictions connected to laïcité, a French model of secularism often described as “closed secularism.”
Laïcité is rooted in a particular historical trajectory. Its origins are commonly traced to the French Revolution of 1789, when the monarchy’s close alliance with the Catholic Church came under scrutiny. Revolutionary leaders sought to redefine authority by replacing religious legitimacy with the sovereignty of the people. In that context, religion was treated as something to be contained within the private sphere rather than exercised as a source of public power. The Revolution’s motto—“liberté, égalité, fraternité”—reflects the idea that a secular public square is part of equality: to make people equal by making them similar.
This approach culminated in the 1905 Law on the Separation of Churches and State. In principle, laïcité formalized two commitments: the neutrality of the state in religious matters and the protection of freedom of conscience. In theory, the goal is to ensure that individuals can believe—or not believe—without coercion, while preventing the state from privileging any religious tradition.
However, laïcité has never been static. Its meaning and application have evolved alongside changes in French society—particularly the growth of religious diversity, including the presence of Islam alongside longstanding Catholic, Protestant, and Jewish communities. Over time, what began as a safeguard against clerical influence has increasingly been applied as a framework for regulating public religious expression.
That shift has generated recurring tensions. Policies such as the prohibition of conspicuous religious symbols in public schools in 2004 and the legislation banning face coverings in 2010 are often defended as expressions of state neutrality and social cohesion. Critics argue that these measures constrain individual religious expression, especially for minority communities.
The workplace is not exempt from this logic. In a case before the United Nations Human Rights Committee, a woman brought a complaint after being fined for wearing a niqab in public. The Committee decided against France in 2018.
Laïcité has also surfaced in professional settings. A French lawyer faced a new rule restricting her from wearing the hijab with her legal gown in court. She challenged the rule through legal channels but lost. The European Court of Human Rights declined to hear the appeal. The result was not only a limitation on religious expression; it meant she could no longer represent clients in court and was effectively pushed away from criminal law.
Laïcité in Belgium has developed somewhat differently from the stricter French model, reflecting a tradition sometimes described as “philosophical pluralism” rather than a full separation of religion and state. Belgium’s Constitution guarantees freedom of religion. Still, employers—including municipalities—may prohibit the wearing of religious symbols at work where neutrality is incorporated into policy. The European Court of Justice upheld this in 2021. In a 2023 case, a Muslim woman challenged her employer, the municipality of Ans, for banning the hijab even when she did not have a public-facing role; the Court upheld the ban as well.
Switzerland illustrates how these issues can vary within a federal system. Geneva, for example, has explicitly embraced laïcité as a guiding principle in public institutions. That approach was shaped by early legal disputes, including a 1996 case involving a primary school teacher who, after converting to Islam, was prohibited from wearing a headscarf in the classroom. Swiss courts upheld the restriction, and the European Court of Human Rights later confirmed that, in that context, the limitation was justified by the need to protect the neutrality of public education and children’s rights.
Geneva later adopted a Law on the Laicity of the State in 2019 requiring public employees—especially those in contact with the public—to refrain from displaying visible religious affiliation, including through dress or symbols. Some parts of that law were overturned, including restrictions relating to elected officials. But voters approved a constitutional amendment on 14 June banning elected politicians from wearing visible religious symbols while performing their duties.
Private employers, by contrast, are generally more accommodating in Geneva and elsewhere in Switzerland. That difference matters. When public institutions set a restrictive standard and private sector practices follow, the overall effect is to shape the environment people experience—not just their legal options.
Quebec has taken this further. Its laïcité law prohibits government workers with front-facing jobs from wearing “visible or invisible” religious symbols. The province relied on the “notwithstanding clause” to shield the legislation from constitutional review. The law has been applied to teachers, police officers, government lawyers, and court workers, and later expanded to include youth protection workers and those working in health services.
More recently, the legal standard for religious accommodation for both public and private employers was reportedly lowered, reducing the threshold to deny accommodation from “undue hardship” to “more than minimal hardship,” meaning employers can reject requests for relatively minor inconvenience.
Across these jurisdictions, the pattern is troubling: even when restrictions are justified in the language of neutrality and unity, they often operate as exclusion in practice. Workers learn that religious expression is acceptable only when it is minimized, hidden, or removed entirely—especially where religious dress is involved. The cumulative message is clear: don’t bring your whole self to work.
If societies are genuinely committed to freedom of religion or belief, they should be able to protect neutrality without punishing religious practice. That requires accommodation where possible and workplace cultures that do not treat faith as a disruption to be managed. True equality does not mean everyone looks the same. True neutrality means people can practice their faith—or not—without being treated as a problem.
Janet Epp-Buckingham, Director, World Evangelical Alliance Office to the UN in Geneva; Executive Editor, International Journal for Religious Freedom.
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