State law covering ESAs in housingHRS § 515-3 — state housing discrimination law with independent enforcementYes
Effect of HUD's May 2026 changeState-law route is independent of HUD enforcementLimited
Minimum client–provider relationshipNo statutory waiting period in HawaiiNone
Pet fees and deposits for an approved ESAAddressed by state law, independently of HUDState law
Penalty for false documentationNo ESA-specific penalty statute; general fraud and misrepresentation law still appliesGeneral law
Public access rights for ESAsIn Hawaii or any state — that is a trained-service-animal right under the ADANone
Where a complaint goesHawaii Civil Rights CommissionHCRC