This study analyzes the level of reasonable accommodation duty in disability
anti-discrimination laws of OECD countries using the comparative law method. The level of
duty to provide reasonable accommodations was measured by four indicators drawn from the
relevant theories. A disability anti-discrimination law is regarded as having a high level of
duty when a) an unjustified failure or refusal to make a reasonable accommodation is regarded
as a form of discrimination; b) the law provides a inclusive definition of reasonable
accommodation or illustrative examples, but not exhaustive examples; c) the concept of
‘reasonableness’ contains the meaning of ‘effectiveness’ of the accommodation; and d) the
law provides that the availability of public funds should be taken into account when determining
whether making an accommodation would amount to a disproportionate burden. According
to these standards, Australia, Austria, Belgium, the Czech Republic, Denmark, France, Greece,
Ireland, the Netherlands, Norway, Slovakia, Spain, and the United Kingdom meet all standards,
while the laws of Hungary, Italy, New Zealand, and South Korea provided a very low level
of duty.