Can a landlord in Pennsylvania deny an ESA accommodation request?

What the law says

Under 24 C.F.R. § 100.204, a housing provider may deny a reasonable-accommodation request only where it would "impose an undue financial and administrative burden" or "fundamentally alter the nature of the provider's operations." HUD's 2020 guidance lists additional factors — direct threat, type of animal, behavior — under which an accommodation may be denied.

Source: HUD FHEO Notice 2020-01: Assessing a Person's Request to Have an Animal as a Reasonable Accommodation Under the Fair Housing Act ↗

In plain language

These narrow denial grounds reflect the pre-2026 federal framework — and the standard that still applies to trained assistance animals. Importantly, HUD's 2026 enforcement memo narrowed federal enforcement to trained service animals, so HUD no longer expects Pennsylvania landlords to accommodate an untrained ESA at all; an untrained ESA's protection now turns largely on Pennsylvania state law (see the protection summary at the top of this page) and on the tenant's private right to sue. A landlord who denies a request should typically provide a written reason. If a tenant believes a denial was improper, the next step is usually a HUD complaint, a state fair-housing complaint, or consultation with a fair-housing attorney in Pennsylvania.