Anyone can train a dog, whether it is for emotional support or something else. The key is that it actually gets trained.

With service dogs, which are different from emotional support animals, the dogs may be trained by service dog programs, by private trainers, or by the owners themselves, assuming they have the necessary skills.

All an ESA needs to know are things like basic house manners, how to not annoy neighbors and visitors, to walk politely on a leash and come when called. Taking obedience classes with your dog is a great activity to do together and a good excuse to get yourself out of the house. But if classes just aren't for you, that doesn't mean you can't have a lovely well-behaved ESA. Most private trainers will do this sort of basic training.

Certification does not make a dog a service dog, or an emotional support dog. Certification is not required in the U.S.

However, in order to keep an ESA in "no pets" housing or to take one on an aircraft, the owner will need some documentation from their physician that the dog's presence is necessary for medical reasons.

Any mentally sound dog will provide an abundance of unconditional love to a caring owner. No training is required for that.