Smart glasses are quickly moving beyond novelty and into the workplace. These wearable devices essentially put a computer into the frame of a pair of glasses, allowing users to access technology while keeping their hands free. As artificial intelligence (AI) advances and wearable devices become more affordable, employers may encounter smart glasses in several ways: an employee may bring them to work, an employer may provide them for business purposes, or an employee may request them as a reasonable accommodation. The challenge is what to do next.
Technology creates an unusual legal intersection. Smart glasses can be an assistive device, a camera, a microphone, and an AI tool all at once. Employers therefore need to consider not only whether employees may use them, but also how the devices fit within disability accommodation obligations, privacy laws, and existing workplace policies.
When Smart Glasses Become an Accommodation
Employees may increasingly request smart glasses as a reasonable accommodation under the Americans with Disabilities Act (ADA). A recent case illustrates the issue.
In Cedeno v. Walt Disney Parks and Resorts U.S., Inc., No. 6:25-cv-02046 (M.D. Fla. Oct. 23, 2025), a Walt Disney World employee alleged visual limitations caused by postpartum conditions and astigmatism affected her ability to see, and her healthcare provider prescribed Meta smart glasses to address those limitations. According to the amended complaint, Disney prohibited her from wearing the glasses at work. She subsequently asserted claims including failure to accommodate, disability discrimination, and retaliation under the ADA. The case remains pending.
Cedeno does not establish that smart glasses are a required accommodation. It does, however, recognize questions employers may face as wearable technology becomes more accessible.
When an employee requests smart glasses as a necessary accommodation, employers should investigate the underlying limitation and the function the device is intended to serve. As with any claim for a disability accommodation, the employer should engage in the interactive process to determine whether the requested accommodation is effective and reasonable, whether it would create an undue hardship on the employer, and whether another accommodation the employer prefers could address the employee’s limitations.
As part of their investigation, employers should consider the employee’s particular job. A device that is appropriate in an office may present very different concerns for an employee who works with customers, handles confidential information, accesses secure areas, or works with protected health information.
Importantly, a general prohibition on cameras or recording devices should not necessarily end the analysis. If an employee is requesting the device because of a disability, the employer should consider the request through the ADA interactive process and document its analysis. As needed, employers should seek competent legal counsel.
Privacy Risks Go Beyond Recording
Smart glasses can create privacy concerns in many circumstances. Employers considering permitting or deploying the technology should determine what the device can capture, whether it records audio or video, whether information is stored or transmitted to a third party, who can access the information, and how long it is retained. Employers should also consider whether the device’s AI capabilities analyze, identify, or otherwise process the information it captures.
Those questions become particularly important as wearable technology moves beyond recording. In June 2026, WIRED reported on an unreleased Meta AI feature internally referred to as “NameTag.” According to the report, the proposed feature was designed to identify people captured by smart-glasses cameras and alert the wearer when a person was recognized. The reported technology would have created facial “faceprints” and compared them against information stored on the user’s phone. Meta subsequently removed this functionality of the software.
The example demonstrates why employers should consider more than traditional surveillance concerns. AI-enabled devices may eventually analyze or identify individuals in ways that trigger additional privacy and biometric requirements.
State laws may already apply. For example, Illinois’ Biometric Information Privacy Act (BIPA) imposes requirements on private entities that collect certain biometric identifiers and information, including information derived from facial characteristics.
Connecticut employers have a similar concern under the Connecticut Data Privacy Act (CTDPA). The CTDPA treats biometric data used to uniquely identify an individual as sensitive data and generally requires consent to process sensitive data. The law also contains requirements concerning data minimization, transparency, and security. The CTDPA’s definition of “consumer,” however, generally excludes individuals acting in an employment or commercial context, making its application to employee information more limited.
California employers also face concerns under the California Consumer Privacy Act (CCPA), as well as California laws governing the recording of confidential communications. California has also considered legislation specifically addressing wearable recording devices. These developments demonstrate the increasingly complex regulatory environment surrounding workplace wearables.
Do Existing Policies Cover Smart Glasses?
Employers do not necessarily need a standalone smart-glasses policy. They should, however, determine whether existing policies adequately address the technology. Employers should review policies concerning:
- Artificial intelligence;
- Cameras and recording devices;
- Electronic monitoring and surveillance;
- Confidentiality and trade secrets;
- Privacy and data security;
- Biometric information; and
- Personal devices and wearable technology.
Policies should also distinguish between employer-issued devices, employee-owned devices, and technology used as a reasonable accommodation.
Just as important, employers should compare their written policies with actual workplace practices. A policy prohibiting recording devices may be difficult to enforce consistently if employees routinely use phones, smartwatches, or other devices to record workplace activity.
Take Action Before the Technology Takes Hold
Smart glasses may be new, but the legal issues they raise are not. Employers already have obligations concerning reasonable accommodations, employee privacy, workplace monitoring, confidentiality, and data security. The challenge is smart glasses can implicate several of these issues simultaneously. Employers should take the opportunity now to:
- Review existing policies addressing AI, recording devices, electronic monitoring, privacy, confidentiality, biometric information, and personal devices.
- Establish a process for accommodation requests involving emerging technology, including documenting the interactive process and considering effective alternatives.
- Evaluate privacy and security risks before permitting or deploying smart glasses, particularly in workplaces involving customers, patients, confidential information, or sensitive data.
- Determine what information the technology collects and whether applicable federal, state, or local laws impose notice, consent, retention, security, or other requirements.
- Train managers and employees on when wearable technology may be used and what information may be captured.
The technology will continue to evolve, and employers do not need to predict every capability that future devices may offer. They should, however, make sure their policies and practices are prepared for the capabilities employees already have in their hands, and increasingly, on their faces.
Brody and Associates regularly advises management on compliance with the latest local, state, and federal employment laws. If we can be of assistance in this area, please contact us at info@brodyandassociates.com or (203) 454-0560.
