Regulation Tracker · Compare countries

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Name: SafeLegalAI Regulation Tracker country comparison
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Country comparison across Regulation Tracker categories.
Question	United Kingdom	United States	European Union	Australia
Must lawyers disclose AI use in court filings?	Proposed / consultation No rule in force. The Civil Justice Council consulted from 17 Feb to 14 Apr 2026 and its 30 June… verified 2026-09-04	Binding rule No judiciary-wide rule. Binding only where an individual judge has issued a standing order: Judge Starr (N.D. Tex.) requires a… verified 2026-09-04	Nothing found No EU-level rule requires disclosure or certification of AI use in court filings; the CJEU Rules of Procedure are silent… verified 2026-09-04	Binding rule Court-ordered or automatic disclosure in most jurisdictions. NSW SC Gen 23 requires affidavits and witness statements to state that Gen… verified 2026-09-04
Must lawyers verify AI output before relying on it?	Official guidance SRA warning notice on misuse of AI (17 Aug 2026) and judiciary guidance require verification of AI output; BSB guidance… verified 2026-09-04	Binding rule Rule 11(b) certification plus ABA Formal Opinion 512 (29 Jul 2024) require verification of AI output before filing. Federal courts… verified 2026-09-04	Official guidance CCBE Guide on the use of generative AI by lawyers (2 Oct 2025) makes lawyers fully responsible for AI-assisted output… verified 2026-09-04	Binding rule Universal. Every Australian instrument imposes a personal duty to verify citations and evidence references. NCAT PD 7 and Victoria's SC… verified 2026-09-04
May judges and court staff use AI in their own work?	Official guidance Judiciary AI guidance for judicial office holders, v3 dated 31 October 2025. Issued for the courts and tribunals of England… verified 2026-09-04	Official guidance The Administrative Office's AI Task Force issued interim guidance judiciary-wide on 31 July 2025 (not published in full). It directs… verified 2026-09-04	Official guidance CEPEJ Guidelines CEPEJ(2025)18Final (19 Dec 2025) govern generative AI use by courts and tribunals across 46 Council of Europe states,… verified 2026-09-04	Official guidance The Chief Justice of NSW issued Guidelines for New South Wales Judges on 21 November 2024, applying to all NSW… verified 2026-09-04
Is AI barred from deciding cases or drafting judgments?	Official guidance Judiciary guidance: AI may not be used to decide cases or draft reasoning; judges remain responsible. verified 2026-09-04	Official guidance No binding prohibition. The July 2025 interim guidance cautions against delegating core judicial functions, including decision making and case adjudication,… verified 2026-09-04	Official guidance CEPEJ(2025)18Final: a human judge must always decide and AI output is never binding. The CJEU AI Ethics Charter (26 Jan… verified 2026-09-04	Official guidance NSW judicial guidelines cl 4-5: judges must not use Gen AI to formulate reasons for judgment or to assess or… verified 2026-09-04
Do self-represented litigants get AI-specific court guidance?	Official guidance Judiciary guidance addresses litigants in person using AI and warns judges to check citations, and it is reinforced by a… verified 2026-09-04	Binding rule Binding only in courts whose standing orders extend to self-represented parties: Judge Starr's certification and Judge Fuentes's order apply to… verified 2026-09-04	Nothing found No EU-level guidance for self-represented litigants using AI; the e-Justice Portal offers no AI-specific advice and the issue is left… verified 2026-09-04	Binding rule Practice notes bind self-represented litigants directly (NSW SC Gen 23, NSW Local Court, NCAT PD 7, GPN-AI, PD-AI). Queensland, Victoria,… verified 2026-09-04
Are AI-generated evidence and deepfakes covered by rules?	Set by case law No AI-specific evidence rule; deepfake and fabricated-document issues handled under existing authentication principles (Lodhia v Twelve Trees, 2026). verified 2026-09-04	Proposed / consultation Proposed Federal Rule of Evidence 707 would apply Rule 702 reliability standards to machine-generated evidence offered without an expert. Comment… verified 2026-09-04	Nothing found Evidence rules are national or Member-State procedural law; the EU has no rule on authenticating AI-generated or deepfake evidence. AI… verified 2026-09-04	Binding rule Affidavits, witness statements and character references must be the maker's own words; Gen AI must not generate their content (NSW… verified 2026-09-04
Can lawyers put client data into AI tools?	Official guidance SRA compliance tips and warning notice: client data must not enter tools without adequate protection or be used for training… verified 2026-09-04	Official guidance ABA Formal Opinion 512 requires informed client consent before confidential information is entered into a self-learning tool. USPTO guidance (11… verified 2026-09-04	Official guidance CCBE guide requires care over professional secrecy, what is entered into tools and where data is processed. EDPB Opinion 28/2024… verified 2026-09-04	Official guidance The December 2024 joint statement of the VLSB+C, Law Society of NSW and Legal Practice Board of WA says confidential… verified 2026-09-04
Does competence include understanding AI risks?	Official guidance SRA guidance applies the competence principle to AI use; BSB guidance reads AI use into Core Duties CD1, CD2, CD3,… verified 2026-09-04	Official guidance Model Rule 1.1 comment 8 (technological competence) as applied by ABA Formal Opinion 512: lawyers must understand the benefits and… verified 2026-09-04	Binding rule AI Act Art. 4 (applicable since 2 Feb 2025) obliges providers and deployers — including law firms deploying AI in… verified 2026-09-04	Official guidance No AI-specific competence rule; the Australian Solicitors' Conduct Rules are applied through guidance. QLS Guidance Statement No. 37 and the… verified 2026-09-04
Must supervisors control AI-assisted legal work?	Official guidance SRA effective-supervision guidance gained AI sections in June 2026; the warning notice names COLP duties. verified 2026-09-04	Official guidance ABA Formal Opinion 512 applies Model Rules 5.1 and 5.3: managerial and supervisory lawyers must establish policies for AI use… verified 2026-09-04	Official guidance CCBE guide recommends firm-level policies, training and human oversight of AI-assisted work; AI Act Art. 14 human-oversight duties bite only… verified 2026-09-04	Official guidance Principals must supervise employees' AI use and set firm policies (QLS GS 37; Law Society of NSW guide; joint regulator… verified 2026-09-04
Must clients be told or asked before AI is used?	Official guidance Law Society guidance recommends transparency with clients. For barristers the BSB goes further: where AI materially impacts the service provided,… verified 2026-09-04	Official guidance ABA Formal Opinion 512 requires informed consent under Rule 1.6 before client confidential information goes into a self-learning tool, and… verified 2026-09-04	Official guidance No EU duty to tell clients about AI use in legal work. AI Act Art. 50(1) requires informing people they… verified 2026-09-04	Official guidance No consent requirement. The joint regulator statement says clients should be told about AI use where it is relevant to… verified 2026-09-04
Can lawyers bill for AI-assisted work?	Nothing found No rule, guidance or reported case found as of 4 September 2026. verified 2026-09-04	Official guidance ABA Formal Opinion 512 holds that a lawyer may not bill for time saved by AI, may not charge the… verified 2026-09-04	Nothing found Lawyers' fees are regulated at Member-State level; no EU rule or CCBE position on billing for AI-assisted work as of… verified 2026-09-04	Official guidance Handled through costs-disclosure obligations rather than a dedicated rule: the joint regulator statement tells practitioners to inform clients where AI… verified 2026-09-04
Are consumer AI legal services regulated as legal practice?	Binding rule Reserved legal activities under the Legal Services Act 2007 apply; the SRA authorised Garfield.Law, the first AI-only firm, in 2025. verified 2026-09-04	Nothing found Unauthorised practice of law is regulated exclusively by the states; no federal rule, ruling or guidance on consumer AI legal… verified 2026-09-04	Nothing found Reservation of legal activities is a Member-State competence; no EU rule or CJEU ruling on AI legal-services products and unauthorised… verified 2026-09-04	Nothing found The Legal Profession Uniform Law prohibits unqualified legal practice, but no Australian ruling, regulator decision or guidance applying it to… verified 2026-09-04
Has the bar or regulator issued generative-AI guidance?	Official guidance Four current documents: BSB 'Guidance on the use of Artificial Intelligence and Other Technologies' (from 18 May 2026), Bar Council… verified 2026-09-04	Official guidance ABA Formal Opinion 512 (29 Jul 2024) is the national ethics baseline. Sector regulators have added their own: USPTO practice… verified 2026-09-04	Official guidance CCBE Guide on the use of generative AI by lawyers (2 Oct 2025) is the pan-European bar guidance: permissive with… verified 2026-09-04	Official guidance Dense. A joint statement of three regulators (6 December 2024), QLS Guidance Statement No. 37 (31 May 2024) and a… verified 2026-09-04
Do courts have rules for their own AI systems?	Official guidance Judiciary guidance covers court-provided tools; HMCTS pilots are not governed by a published rule. verified 2026-09-04	Official guidance The AO established an advisory AI Task Force in early 2025 and issued interim guidance on 31 July 2025 covering… verified 2026-09-04	Official guidance The CJEU adopted an AI Strategy on 19 June 2023, created an AI Management Board, and adopted an AI Ethics… verified 2026-09-04	Official guidance Addressed inside the judicial guidelines rather than a standalone deployment policy: NSW guidelines govern associates, tipstaves and researchers; Victoria's judicial… verified 2026-09-04
Do data-protection rules specifically govern legal AI?	Official guidance ICO guidance on AI and data protection applies to legal services generally. verified 2026-09-04	Nothing found There is no federal comprehensive data-protection statute and no federal DPA guidance addressed to AI in legal services; confidentiality of… verified 2026-09-04	Official guidance EDPB Opinion 28/2024 (17 Dec 2024) addresses AI-model anonymity, legitimate interest in development and deployment, and consequences of unlawful training… verified 2026-09-04	Official guidance OAIC guidance on privacy and the use of commercially available AI products (21 October 2024, updated 17 January 2025) applies… verified 2026-09-04
Does a horizontal AI law classify legal or justice uses?	Nothing found No horizontal AI statute; the EU AI Act reaches UK firms only when output is used in the EU. The… verified 2026-09-04	Nothing found No federal AI statute and no risk classification of justice-sector uses. The Executive Order of 11 December 2025, Ensuring a… verified 2026-09-04	Binding rule AI Act Annex III point 8(a) classifies AI intended to assist judicial authorities in researching/interpreting facts and law, or in… verified 2026-09-04	Proposed / consultation No horizontal AI statute. DISR consulted in September 2024 on mandatory guardrails for AI in high-risk settings alongside a Voluntary… verified 2026-09-04
Have courts sanctioned AI misuse?	Set by case law Ayinde v Haringey and Al-Haroun (Divisional Court, June 2025) set the framework: wasted costs, contempt, regulatory referral. Applied since in… verified 2026-09-04	Set by case law Federal courts sanction AI misuse under Rule 11, 28 U.S.C. 1927 and inherent power. Mata v. Avianca (S.D.N.Y. 2023) set… verified 2026-09-04	Nothing found No EU-level sanctions framework for AI misuse in litigation; sanctions for hallucinated citations are imposed by national courts and bars.… verified 2026-09-04	Set by case law The largest body of AI-citation case law outside the United States (110 Australian decisions in the Charlotin database at 4… verified 2026-09-04
Do arbitration or ADR rules address AI?	Official guidance Ciarb Guideline on the Use of AI in Arbitration (Mar 2025, updated Sept 2025) is the reference text for London-seated… verified 2026-09-04	Official guidance The AAA-ICDR issued Guidance on Arbitrators' Use of AI Tools (2025): AI must support not replace the arbitrator's judgment, and… verified 2026-09-04	Nothing found No EU instrument on AI in arbitration or ADR. The relevant instruments in Europe are institutional (e.g. CIArb 2023 guideline)… verified 2026-09-04	Not yet determined Not established. No ACICA, Resolution Institute or equivalent Australian arbitration AI guideline was located before the search budget was exhausted;… verified 2026-09-04
Is AI training mandatory for lawyers?	Nothing found No mandatory AI training requirement found as of 4 September 2026. Continuing competence is outcomes-based for both solicitors and barristers. verified 2026-09-04	Nothing found No federal mandatory AI training requirement. Continuing legal education is a state function; several states have added technology or AI… verified 2026-09-04	Binding rule AI Act Art. 4 imposes an outcome-based AI literacy duty on deployers from 2 Feb 2025, but prescribes no course,… verified 2026-09-04	Nothing found No mandatory AI-specific CPD requirement found in any Australian jurisdiction as of 4 September 2026. Law societies (Tasmania, Queensland, New… verified 2026-09-04
Must legal AI vendors pass procurement due diligence?	Official guidance SRA compliance tips address due diligence on technology suppliers; BSB guidance requires barristers to assess whether a tool is suitable… verified 2026-09-04	Official guidance The AO's July 2025 interim guidance addresses procurement and security of AI tools for courts. For executive-branch legal offices, OMB… verified 2026-09-04	Official guidance CCBE guide asks lawyers to check tool terms, data location and training-data use before adoption. AI Act value-chain duties (Art.… verified 2026-09-04	Official guidance The Law Society of NSW guide tells firms to select tools with appropriate data protections; QLS publishes an AI checklist… verified 2026-09-04