General counsels’ strategic responsibilities are growing /// Sanctions dominate the agenda of European legal departments

• Data protection, M&A and geopolitical risks are the most relevant legal issues for the board of directors
• 69 percent plan to increase investment in generative artificial intelligence (AI) within their legal departments
• European companies in particular are satisfied with their initial AI trials

Reporting Lines and Titles

84 percent of respondents report directly to the Chief Executive Officer (CEO), 42 percent exclusively or additionally to the Chief Financial Officer (CFO), and 17 percent to the Chief Operating Officer (COO). While more than half (55 percent) indicated they are referred to as "General Counsel" within their own organization, one in three (34 percent) globally holds the title "Chief Legal Officer." In Europe, this is already the case for one in five (21 percent).

"The figures show that legal departments are now systematically involved earlier and more closely in business decisions," says Stefan Heissner, Head of Forensic & Litigation at FTI Consulting DACH. "Strategic projects—such as market entries, major investments, or M&A transactions—are considered from a legal perspective from the outset. This requires General Counsel to have a strong understanding of business models and value creation, as well as the ability to argue not only legally but also in the language of management."

One in Three European Chief Legal Officers Names Sanctions as a Priority

While formal integration is increasing, the substantive focus of the work is simultaneously shifting. In Europe, 61 percent of chief legal officers report that their expertise is particularly sought at board level in the area of data protection. Equally relevant are mergers & acquisitions (M&A) and geopolitical risks (57 percent each). For 48 percent, ESG continues to play a central role—significantly more than the global average (26 percent).

A particularly pronounced difference is evident on the topic of sanctions: for 34 percent of European companies, they rank among the most important regulatory issues. Overall, European General Counsel rate them as the second most important threat area for their companies after industry-specific regulation (61 percent). Globally, however, only 13 percent cite sanctions as a priority topic. There is greater consensus on dealing with tariffs: 30 percent (globally) and 29 percent (Europe) see this as a central challenge.

"European companies operate in a highly complex sanctions environment. The war in Ukraine has further intensified this dynamic," says Stefan Heissner. "Investment decisions, supply chains, or financing structures can be reassessed from a regulatory perspective within a short time. This forces companies to continuously integrate geopolitical developments into their decision-making processes. The legal department thus becomes a central authority for risk transparency."

At the same time, the study shows that regulatory requirements are increasing worldwide overall. Decisions must increasingly be made taking into account multiple, sometimes conflicting, jurisdictions.

"It's not just about avoiding sanctions or fines," says Stefan Heissner. "Companies must structure their business models so that they can withstand regulatory volatility. This requires legal scenario analyses—and close coordination with the board and operational units."

AI Investments Are a Structural Response to Rising Requirements

Parallel to rising regulatory requirements, legal departments are investing massively in technology. 69 percent of General Counsel surveyed worldwide indicate that their companies will invest more heavily in Generative Artificial Intelligence over the next 24 months. In Europe, this figure is even higher at 77 percent.

This makes AI by far the most important technological investment in the legal sector—ahead of contract management software (55 percent) and document management (24 percent). 36 percent are already testing AI applications in individual cases. In Europe, 24 percent of respondents report being very satisfied with the results to date—a significantly higher figure compared to the global average (14 percent).

At the same time, very few expect their departments to shrink: only nine percent worldwide anticipate staff reductions, 63 percent expect stable structures, and four percent even anticipate job growth. 23 percent consider a reliable forecast premature at this time.

"Investments in AI are not a short-term efficiency measure, but rather a structural adjustment to permanently rising requirements," says Renato Fazzone, Co-Head of the Technology Segment at FTI Consulting in Europe (EMEA). "Legal departments today must analyze and evaluate large volumes of data from internal systems, emails, contracts, and external sources. Without technological support, this is hardly possible in a reasonable timeframe."

At the same time, the use of AI creates new questions. "Companies must be able to understand how AI-supported decisions are made, what data is used, and what risks arise from this," says Renato Fazzone. "For forensic practice, it will be crucial in the future to analyze interactions between humans and AI in a traceable manner. This is a new field of review and assessment that legal departments should prepare for early on."

About the Study:

The Chief Legal Officer (CLO) Survey 2026 is an annual international survey conducted by the Association of Corporate Counsel (ACC) in cooperation with FTI Consulting. In the current edition, 1,049 General Counsel and Chief Legal Officers from 43 countries and 20 industries were surveyed. The study examines key trends in the role of legal departments, their integration into boards and management, regulatory challenges, as well as technological and personnel developments. In addition to the global overall report, regional special evaluations, including for Europe, are available.

The complete study is available here:

https://www.ftitechnology.com/resources/white-papers/2026-acc-chief-legal-officers-survey

About FTI Consulting

FTI Consulting, Inc. is a global leader in consulting for companies in crisis and transformation with more than 8,100 experts in 32 countries and territories as of December 31, 2025. In certain countries, FTI Consulting's services are provided through independent legal entities that are separately capitalized and independently managed. FTI Consulting achieved revenues of $3.8 billion in fiscal year 2025. For more information, visit www.fticonsulting.com

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