What clients now tell their law firms about AI.

Outside-counsel guidelines are the rules a client gives the law firms it hires. They cover billing, staffing, confidentiality, and reporting, and some now cover AI. Most organizations hand them to their firms through a portal and never publish them. The organizations that do publish are mostly public bodies and universities, and the sample shows it. 86% of the 1,054 come from them and 24 are companies. We gathered the documents on September 15 and 16, 2026, through search engines, sweeps of company, insurer, public-body, and university websites, procurement portals, and court dockets where guidelines had been filed as exhibits. A document qualified if it governs an organization's use of outside law firms, whether it is written to the firms, like billing guidelines, or to the organization's own staff, like the legal-services policies most universities outside the United States publish. It is a sample, limited to what search engines and procurement portals surface.

We kept only guidelines written after ChatGPT was released. A document counted when it carried a date of December 2022 or later in its own text, in its file's metadata, in the page's tags, or in the address it was published under. Among the documents we read in full, we left out 55 older guidelines and 15 that could not be dated. At the screening stage we set aside 1,001 more because they carried a date before December 2022 and 145 because we could not date them. 12 organizations publish a page with no date on it. Where that page is the current version on the organization's own site, we counted it. That left 1,054 documents from 1,054 organizations: 832 from public bodies, 74 from universities, 33 from nonprofits, 25 from health systems, 24 from companies, 21 from pension funds, 20 from banks, 15 from insurers, 10 from others.

We searched every document in full for the words of AI in the document's own language, whether that was English, Italian, Polish, or Vietnamese. The words were artificial intelligence, generative AI, machine learning, large language models, ChatGPT, Copilot, and their variants, and scanned files went through OCR first. 254 of the 1,054, including every document where one of those words appeared, were then read in full and coded against a fixed rubric. The rubric asks whether the document mentions AI and, if it does, whether it requires the firm to disclose AI use, to get consent first, to keep the client's information out of public tools, to have a lawyer check the output, to use approved tools only, to hold an AI policy of its own, or to bill differently. A clause counted only when the document says it, and every yes comes with the document's own words, which are in the CSV. A ban that lifts on consent is coded as consent, and a rule that the firm must get approval before using AI is coded as disclosure too, since the firm has to say so first. Where an organization publishes several guideline pages, we read them together and counted the organization once. 2 documents could not be read: Bayer AG (the site blocked automated requests), and Gloucester, Salem, Cumberland Counties Municipal Joint Insurance Fund (TRICO JIF) (the published copy is missing half its pages).

Dates come from the documents. 1,042 of the 1,054 have one. The 12 without a date are live pages on their organizations' own sites. They count in the study and appear in the table, and we left them off the timeline.

The data is the table below and the CSV, released under CC BY 4.0 with attribution to Fulkerson Advisors. If your organization publishes guidelines we missed, email info@fulkersonadvisors.com and we'll add them.

Fulkerson Advisors (2026). What Clients Now Tell Their Law Firms About AI: 1,054 Outside-Counsel Guidelines Searched. Read September 16, 2026. https://www.fulkersonadvisors.com/research/ai-in-outside-counsel-guidelines

Use any of these numbers or quotes. Credit Fulkerson Advisors and link to this page. The data is under a CC BY 4.0 license.

The data is also on Zenodo, DOI 10.5281/zenodo.23320135.