How to Verify an ESA Letter: A Guide for Housing Providers

A property manager holding an assistance-animal letter is in an awkward position. The market genuinely does contain sites that will sell a signed PDF after a two-minute questionnaire, so scepticism is not unreasonable. But the cost of getting it wrong runs in both directions: accept everything and the pet policy means nothing, refuse too readily and the refusal itself becomes the violation.

This is a working guide to the middle path — what you may lawfully ask, what you may never ask, and how to check a document in a way that produces an answer rather than an argument.

Start with the inquiry you are not allowed to make

Most of the trouble in this area comes from a question asked in good faith.

24 C.F.R. § 100.202(c) makes it unlawful to make an inquiry to determine whether an applicant for a dwelling, a person intending to reside in it, or any person associated with them has a handicap, or to make inquiry as to the nature or severity of a handicap.

Read that twice, because it rules out a set of questions that feel natural:

• What condition do you have?
• How long have you had it?
• What are your symptoms?
• Can I see your medical records?
• Which medications are you on?
• Can your doctor explain why an animal helps rather than treatment?

None of that is yours to ask, and none of it is required for you to decide. The question you are actually answering is narrower: does this person have a disability, and is the animal needed because of it? You are entitled to information establishing those two things. You are not entitled to the story behind them.

What you may ask for

Where the disability or the disability-related need is not readily apparent, you may ask for information supporting the request. That is a real entitlement and it is worth using properly.

Several states have legislated the point rather than leaving it to practice. Pennsylvania’s Act 118 of 2018 permits a request for documentation where the disability or need is not readily apparent, and requires that documentation be in writing, reliable, and based on direct knowledge. Florida’s Fla. Stat. § 760.27(2)(b) sets out what supporting information may be requested and expressly contemplates information from a health care practitioner or a telehealth provider.

Notice what those standards ask about: the relationship behind the signature, not the format of the document. “Reliable and based on direct knowledge” is a question about whether the professional actually knows this person. That is the right question, and it is the one a verification process should be built around.

Check your source: the 2020 guidance is withdrawn

Before applying anything you have read elsewhere, check its date.

HUD’s Office of Fair Housing and Equal Opportunity withdrew FHEO Notice 2020-01 on assistance animals, along with FHEO 2013-01, effective 17 September 2025 (91 FR 17291, Docket FR-6571-N-01). A great deal of landlord-facing advice still circulating online — including checklists and training materials — rests on that notice as though it were current.

The regulations did not change. 24 C.F.R. § 100.204 still makes it unlawful to refuse to make reasonable accommodations in rules, policies, practices or services when such accommodations may be necessary to afford a person with a disability equal opportunity to use and enjoy a dwelling — and that regulation’s own worked example is a building with a no-pets policy that must admit an assistance dog. Section 100.202(c) still limits inquiry. What went away was a layer of interpretive guidance, not the duty.

The practical consequence: if a policy document in your office cites the 2020 notice as authority, it needs reviewing. Citing withdrawn guidance to a tenant is a weak position to argue from.

The universal check: look up the licence

This works for any letter from any source, costs nothing, and takes about two minutes.

Every state publishes a licence lookup for its health professions — boards of psychology, behavioral health, social work, medicine. Take the name and the licence number printed on the letter and search the board’s register in the state named on the document.

You are confirming four things:

1. The person exists and holds the credential claimed
2. The licence is active, not lapsed, suspended or surrendered
3. The licence is in the state whose register you searched
4. The name matches the signature

A letter that fails this is a genuine problem and you are on firm ground saying so. A letter that passes has cleared the bar that actually matters, and the remaining objections people reach for — the letter came from telehealth, the provider is not local, the format looks unfamiliar — are not reliability findings.

One nuance worth knowing: a clinician may lawfully practise across state lines under an interstate compact, such as PSYPACT for psychologists or the equivalent arrangements for counselors and social workers. A licence issued elsewhere is not automatically a defect if compact authority covers your state. Florida takes a stricter line and treats an out-of-state practitioner as reliable only where they have provided in-person care to the person on at least one occasion, which is a state-specific rule rather than a general one.

Contacting the professional

You may confirm that a named licensee wrote and signed the document. That is an authenticity question and it is fair.

What you may not do is turn the call into the inquiry § 100.202(c) forbids. Asking the clinician to describe the condition, justify the recommendation clinically, or confirm a diagnosis is the same prohibited inquiry routed through a third party, and a professional who answers those questions without authorisation has their own problem. Keep it to: did you write this, is it yours, is the licence information correct.

Expect this route to be slow. Clinicians are not obliged to be reachable on your schedule, and a delay in reaching one is not evidence that a letter is false.

What a registry number, ID card or certificate proves

Nothing — in either direction.

No government ESA registry exists, federal or state. Nothing sold online places an animal on an official list, and no landlord is required to accept a card. Florida legislated the point at Fla. Stat. § 760.27(3)(c): an ESA registration of any kind obtained from the internet is not by itself sufficient information.

Two errors follow from misunderstanding this, and both are common:

• Demanding a registration number. There is no such thing to demand. A policy requiring one imposes a condition the law does not recognise.
• Rejecting a request because a card was produced. A tenant who bought an ID card alongside a genuine letter has bought a redundant item, not invalidated their documentation.

Assess the letter. Ignore the merchandise.

Instant verification, where the issuer supports it

Licence lookup tells you the signer is real. It does not tell you whether this document is the one they issued — a PDF is trivially editable, and a real clinician’s name and licence number can be lifted onto a letter they never wrote.

Some issuers now close that gap directly. Letters issued through Support Animal carry a unique letter number and a QR code tied to that specific document, and a housing provider can check one at my.supportanimal.com/verify without an account, two ways:

• By letter number — the patient’s first and last name plus the letter number printed on the document
• By file upload — submit the PDF itself, which is matched against what was actually issued

The result answers the authenticity question and stops there: this document was genuinely issued through the platform by that provider, or it was not issued at all. Records are immutable and audited once a letter is issued, so an altered PDF does not match and a fabricated one has nothing to match against. Pet registrations can be confirmed the same way, by registration number and the animal’s name.

Two limits are deliberate, and both protect you as much as the tenant. No protected health information is disclosed — you will not receive a diagnosis or clinical detail, because you are not entitled to it and a verification tool that handed it over would be walking you into the inquiry § 100.202(c) forbids. And uploaded files are not stored; they are used for the check itself.

As of July 2026, we know of no other emotional support animal provider that verifies the letter file itself rather than a reference number typed off it. Several services let you check a code against a registry, and a couple of specialist screening companies will review a submitted letter by having staff telephone the clinician over the following day or two.

When a letter does not verify

An unverifiable letter is a reliability problem. It is not an automatic denial, and treating it as one is how a documentation dispute becomes a fair housing complaint.

Do this instead:

1. Say specifically what you could not confirm. “The licence number on this letter does not appear on the Ohio board register” is a finding. “This letter isn’t valid” is not — and a tenant cannot fix an objection you have not articulated.
2. Say what would resolve it. Name the information you need.
3. Keep the request open while it is resolved. The accommodation request is live; the paperwork question is a step inside it.
4. Put it in writing and date it. If this is ever assessed by anyone else, they will read a file.

A tenant whose letter came from a mill is often not a bad actor. They paid a site that promised a legitimate document and received something thinner than advertised. Told clearly what is missing, most will go and get a proper evaluation.

The charges that create liability

Once an accommodation is approved, charges tied to the animal do not survive it. Pet rent, pet deposits and one-time pet fees are charges for keeping a pet, and an approved assistance animal is not being kept as one. Breed lists and weight limits do not apply to it either — those are precisely the “rules, policies, practices or services” § 100.204 requires to give way.

What you keep:

• Liability for damage the animal actually causes, assessed at move-out like any other damage
• Any generally applicable deposit, subject to your state’s cap
• The right to act against a specific animal whose behaviour warrants it

That last one is narrow and individualised. The statutory exception at 42 U.S.C. § 3604(f)(9) concerns a tenancy that would constitute a direct threat to the health or safety of other individuals, or would result in substantial physical damage to the property of others. It is about this animal’s conduct, evidenced. A breed’s reputation is not evidence, and a policy applied categorically is not an individualised assessment.

State rules that change the answer

The federal floor is the same everywhere; several states add to it, and the additions run in both directions.

Check your own state before applying a rule you read about another one. A Florida standard quoted at an Arizona tenant is not authority.

A two-minute checklist

• Is the disability or the need not readily apparent? Only then does a documentation request arise
• Does the letter name a professional, a credential, a licence number and a state?
• Does that licence appear as active on the state board register?
• Is there an issuer verification route — a letter number, a QR code, an upload check?
• Have you avoided every question about the condition itself?
• If you are refusing, have you written down what was unsatisfactory and what would fix it?

Get those six right and you are both compliant and rigorous, which is the combination worth having. For what a defensible letter contains in the first place, see our guide to getting an ESA letter; for the narrow grounds on which a request may lawfully be refused, see when a landlord can deny an emotional support animal.