The AI Legal Counsel characterises the organisation’s legal position on AI: provider versus deployer versus distributor, prohibited practices, substantial modification, notify duties, contract risk, multi-entity attribution, and privilege. Role 1.1 Directs. Role 1.2 owns conformity readiness. Role 1.4 files residual risk. Role 8.6 transmits notices. This role says what the law requires those roles to treat as true — and records that advice under privilege where appropriate.

Standing duties

• Characterise role under the Act for each in-scope system and component, including role-flip when the organisation substantially modifies a provider model.
• Advise ACT02 when facts would change legal role, class, or prohibited-practice proximity. Advise ACT03 when production facts already have.
• Set the legal bar for contracts Role 7.1 negotiates and for notices Role 8.6 packs.
• Keep characterisation current with the live estate — a memo about last year’s architecture is a defect.
• Do not treat a legal memo as residual-risk acceptance, as REV03 readiness, as REV04 assurance, or as a substitute FRIA or DPIA.

Accountable to: General Counsel / Board (privilege). Coordinates with Role 1.1 and Role 1.2

Primary domain: Establish (legal characterisation) and Act advice. Does not own REV03, REV04, or residual-risk acceptance.

Linked EN 18286 clauses: 4.2, 4.4.2, 9.4, 10.1.1.2

Format: 3 hours of training, EUR 200.