Mental Health, Neurodivergence, and Substance Use: What Does the Duty to Accommodate Actually Mean in 2025?
Quick take: The duty to accommodate in 2025 isn’t about “who has what diagnosis.” It’s about whether your work design lets people meet essential job demands with less executive-function (EF) load, less stigma, and clear fit-for-duty pathways. Here’s the research-backed picture—plain language, defined terms, and what to watch.
What’s changed about the duty to accommodate in 2025?
Canada’s guidance has converged on function over diagnosis (CHRC, 2024; ASC, 2025). The Canadian Human Rights Commission (CHRC) emphasizes a duty to inquire when patterns suggest a need and requires only job-related information tied to essential duties—not labels or full medical details (CHRC, 2024).
The 2025 Accessibility Standards Canada employment stipulations ask organizations to run a documented, end-to-end support system (policies, roles, accessible tech) that doesn’t depend on disclosure (ASC, 2025).
In short: tune the job first, then tailor the person–task fit.
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Key terms
Executive Function (EF): Mental skills for planning, prioritizing, time management, and working memory.
Impression Management (IM): The ways we present ourselves to others (e.g., “polish,” small talk).
Camouflaging: A form of IM—masking or compensating to appear neurotypical, often effortful (Khudiakova et al., 2025).
Fit-for-duty: A safety standard that indicates if someone can safely perform essential tasks right now (CHRC, 2024).
How can I plan workplace accommodations by mapping job demands (not diagnoses)?
The Job Demands & Accommodation Planning Tool (JDAPT) maps a role’s specific demands (attention, time pressure, stamina, social load, working conditions) and helps a worker pick practical strategies.
In a 9-month Canadian evaluation, JDAPT use was linked to higher self-efficacy (confidence) and lower presenteeism (hidden productivity loss), with some absence improvements (Gignac et al., 2025). Notably, many wins came from low-permission changes (e.g., pacing, micro-breaks, meeting hygiene, task sequencing)—not diagnosis-heavy processes (Gignac et al., 2025).
So what? Start the conversation with job tasks, not labels; you’ll get traction sooner and with less disclosure risk (Gignac et al., 2025).
How can I reduce cognitive load on my team?
Cognitive overload is the modern hazard. Employees screening for ADHD report much higher burnout, and the gap is partly driven by executive-function (EF) deficits (Turjeman-Levi et al., 2024).
Two levers stand out:
1) self-management to time → physical fatigue (Turjeman-Levi et al., 2024)
2) self-organization/problem-solving → emotional exhaustion and cognitive weariness (Turjeman-Levi et al., 2024)
That’s a design problem: too many meetings and context switches, calendars without buffers, and unclear decision paths/success criteria push EF load up (Turjeman-Levi et al., 2024).
So what? Redesign the system—time architecture (weekly priority triage, protected deep-work blocks, 25/50-minute defaults, visible WIP limits) and problem-solving scaffolds (standard task cards with goal/constraints/success signals/next step; simple decision trees)—and pair with low-permission supports that already show drops in presenteeism and boosts in confidence (Gignac et al., 2025; Turjeman-Levi et al., 2024).
Are people masking at work to fit in—and are we rewarding it?
Often, yes. Research reframes camouflaging as context-driven impression management (IM) (Khudiakova et al., 2025). Respondents with autism reported costs (anxiety, exhaustion, burnout), and those costs rise when environments reward “polish,” face time, and fast verbal processing over clear written contribution and turn-taking (Khudiakova et al., 2025).
So what? Reduce coercive IM: use structured interviews, explicit meeting roles, written/async options, and permission to pass/return to lower effort and widen participation (Khudiakova et al., 2025).
Why don’t employees disclose accommodation needs—even when we have a policy?
Two multipliers: stigma and manager readiness. Workers frequently keep strategies private; disclosure can feel risky (especially in low-control or low-wage roles) (Gignac et al., 2025). Evidence shows supervisors make or break accommodations—when they lack scripts, confidence, or authority, nothing moves (McArthur et al., 2025).
So what? Train to the moment of use: how to notice patterns, open a duty-to-inquire check-in without diagnosing, map demands (JDAPT style), and activate a low-permission menu fast (McArthur et al., 2025; CHRC, 2024; Gignac et al., 2025).
How should we handle substance use & impairment at work?
Treat impairment as a system signal. In safety-sensitive positions, use near/during work is not rare—about 20% of workers and 35% of managers reported alcohol/other drug use within two hours before work, during work, or being hungover/high at work (McIlwaine et al., 2025).
Culture permits more than leaders assume: 19% said their workplace generally accepts alcohol/cannabis before or during work, and 21–40% view substance use as a workplace issue (McIlwaine et al., 2025). And stigma blocks early help: only 56% felt it was safe to disclose concerns, and among those who used near/during work, 51% said they usually hid it (McIlwaine et al., 2025).
Another key concern: supervisors aren’t ready—43% did not feel adequately trained to intervene (McIlwaine et al., 2025). Upstream drivers matter: physically demanding work and pain push some toward substances for coping (McIlwaine et al., 2025). Encouragingly, return-to-work acceptance is high: 82–83% were comfortable with same or modified duties post-treatment (McIlwaine et al., 2025). (Part 2 of this article will include supports on this topic!)
So what? Align policy + culture: one harmonized impairment policy with clear fit-for-duty steps, annual scenario-based manager training, and MSD/fatigue controls to address root causes—paired with de-stigmatized, confidential supports and a quarterly pulse on acceptability, disclosure safety, manager readiness, and near-miss/impairment reports (McIlwaine et al., 2025).
Which metrics should we track before rolling out accommodations?
Job disruptions: How often are people losing time, avoiding extra duties, blocked from promotion/transfer, or unable to access preferred shifts? (Jessiman-Perreault et al., 2025).
Confidence & friction: Are self-efficacy scores rising and presenteeism falling after low-permission changes? (Gignac et al., 2025).
EF signals: Meeting creep, missing buffers, unclear decision paths (Turjeman-Levi et al., 2024).
Stigma & readiness: Do people feel safe to raise needs? Do supervisors feel equipped to intervene? (McArthur et al., 2025; CHRC, 2024).
Safety pulse: Perceived acceptability of substance use near/during work; near-miss reporting; manager confidence (McIlwaine et al., 2025).
Up next (in Part 2): A manager-ready operating update—moves to reduce EF load, de-risk disclosure, and respond to impairment safely, mapped to Canada’s legal and standards landscape.
Wondering where to start?
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References
Accessibility Standards Canada. (2025, May). CAN/ASC-1.1:2024 (REV-2025) — Employment. Accessibility Standards Canada. https://accessible.canada.ca/creating-accessibility-standards/summary-can-asc-112024-rev-2025-employment
Canadian Human Rights Commission. (2024, May 10). Workplace accommodation — A guide for federally regulated employers. https://www.chrc-ccdp.gc.ca/resources/publications/workplace-accommodation-guide
Gignac, M. A. M., Thompson, A., Tompa, E., Bowring, J., Navaratnerajah, L., Saunders, R., Jetha, A., Shaw, W. S., Macdermid, J. C., Franche, R.-L., Van Eerd, D., Irvin, E., & Smith, P. M. (2025). The Job Demands and Accommodation Planning Tool (JDAPT): A nine-month evaluation of use, changes in self-efficacy, presenteeism, and absenteeism in workers with chronic and episodic disabilities. Journal of Occupational Rehabilitation, 35, 625–640. https://doi.org/10.1007/s10926-024-10231-w
Government of Canada. (2024, April 3). How to talk to a family member or friend about their drug or alcohol use. https://www.canada.ca/en/health-canada/services/substance-use/talking-about-drugs-alcohol/how-to-talk-to-someone.html
Jessiman-Perreault, G., Smith, P. M., Thompson, A., & Gignac, M. A. M. (2025). The relationship between meeting workplace accommodation needs and job disruptions among Canadians working with disabilities: A cross-sectional analysis. Journal of Occupational and Environmental Medicine, 67(1), e54–e59. https://doi.org/10.1097/JOM.0000000000003262
Khudiakova, V., Alexandrovsky, M., Ai, W., & Lai, M.-C. (2025). What we know and do not know about camouflaging, impression management, and mental health and wellbeing in autistic people. Autism Research, 18, 273–280. https://doi.org/10.1002/aur.3299
McArthur, R., Williams, J., & Kneipp, S. (2025). Workplace accommodations for low-wage workers: A scoping review. Work: A Journal of Prevention, Assessment and Rehabilitation, 81(2), 2444–2457. https://doi.org/10.1177/10519815241312597
McIlwaine, S., Meister, S., Barker, B., Dassieu, L., Noorbakhsh, S., Panesar, B., & Beirness, D. (2025, July). Workplaces and substance use: Safety-sensitive positions [Research brief]. Canadian Centre on Substance Use and Addiction.
Turjeman-Levi, Y., Itzchakov, G., & Engel-Yeger, B. (2024). Executive function deficits mediate the relationship between employees’ ADHD and job burnout. AIMS Public Health, 11(1), 294–314.
