As legal and business environments grow more complex, chief legal officers in Europe are facing expanding expectations with limited additional resources. They are no longer viewed only as legal advisors but increasingly as strategic leaders who guide their organizations through regulatory change, technology adoption, and geopolitical uncertainty.
The 2026 European Supplement to the ACC Chief Legal Officer Survey offers insights into how legal leaders across Europe are responding to these pressures. The survey is based on responses from CLOs in more than 40 countries and reflects how legal departments are adjusting priorities amid rapid external change.
Trade, tariffs, and regulation dominate priorities
One of the most significant shifts for European CLOs is the growing impact of geopolitical developments on daily legal work. Trade policy, sanctions, and tariff regimes have become central concerns.
30% of surveyed CLOs identified trade and tariff issues as a top priority, reflecting how political developments are increasingly shaping international business decisions. AI regulation also saw the largest year-over-year increase among regulatory concerns, rising by 21%.
About half of legal departments reported dedicating additional time and resources to business changes driven by new government policies and regulations. This includes monitoring national implementations of EU digital legislation and responding to shifting enforcement expectations.
To manage this complexity, many CLOs are relying more heavily on external expertise. 48% reported increased use of outside counsel, while 27% turned to consultants for specialized regulatory support.
AI literacy becomes a core leadership skill
Artificial intelligence is no longer viewed only as a technical tool. It is now part of the leadership profile expected of CLOs. Nearly half of CLOs said their CEOs expect them to develop stronger technology and AI proficiency. This represents a change from traditional legal leadership models that focused primarily on legal risk management and compliance.
European legal departments are approaching AI adoption pragmatically. 36% are already actively deploying generative AI tools, mainly to support document drafting and analysis. Rather than reducing headcount, most departments are using AI to improve efficiency and allow lawyers to focus on higher-value work.
63% of CLOs expect their team size to remain stable, while investment is shifting toward upskilling existing staff. This reflects a broader strategy of integrating technology into legal operations without disrupting organizational structures.
Budget pressure limits transformation efforts
Despite growing responsibilities, resource constraints remain a central challenge. 35% of CLOs identified budget and staffing limitations as their main barrier to success. Legal departments are expected to support business transformation initiatives while also managing compliance, litigation, and regulatory monitoring.
Consequently, operational efficiency has become a top strategic goal. CLOs are increasingly focused on simplifying workflows, prioritizing high-risk matters, and improving collaboration with business teams.
This includes rethinking how legal services are delivered internally. Many departments are exploring new service models that combine in-house expertise, technology tools, and targeted external support.
External risks outweigh traditional legal concerns
The survey also shows a shift in how CLOs define risk. Instead of focusing primarily on litigation or data privacy, European CLOs are more concerned with barriers to business growth and expansion. 20% cited macro-level business risks as their primary concern, compared to only 4% who identified litigation or data protection as top priorities.
This reflects a broader change in the CLO role. Legal leaders are now expected to anticipate market risks, support strategic planning, and contribute directly to corporate resilience.
Cybersecurity remains relevant, but it is no longer viewed in isolation. It is part of a wider risk landscape that includes supply chain disruption, political instability, and regulatory fragmentation.
CLOs strengthen ties with CEOs
Reporting structures further highlight the evolution of the CLO role. 48% of CLOs now report directly to their CEOs, the highest level recorded in the survey’s history. At the same time, direct reporting to boards has declined, though more than half maintain regular communication with board members.
This closer alignment with executive leadership underscores the strategic position CLOs now occupy within organizations. They are increasingly involved in decisions related to investment, expansion, and digital transformation.
According to the survey, CLOs are becoming central contributors to enterprise resilience. Their role combines legal judgment with business insight, technology awareness, and risk forecasting.
Wafik Guirgis, Senior Managing Director and global co-leader for FTI Technology’s Legal Operations Consulting and Contract Solutions practice, added to this:
“The ACC CLO data highlights that organizations are formally recognizing the value of counsel as a strategic business partner and changing the long-held perception of legal being the ‘department of no’, to instead a lead partner on ‘how best to go.’ CLOs are uniquely qualified to balance the pursuit of strategic business ventures while making best attempts to insulate their institutions from geopolitical risks, quickly shifting trade policies, and regulatory changes. The stakes can be high in the current environment, so getting any of these wrong can directly affect company performance in the form of eroding profit margins, disrupting supply chains, and limiting commerce. The role of counsel as the chief horizon scanner is proving to be invaluable in every aspect of business.
The data supports that AI is underscoring the ever-important and critical trait of nimbleness on the part of the CLO on yet another front. Techno (and now AI) literacy is becoming a critical component of continuous improvement as CLOs embark on how best to improve legal operations, as well as support internal business partners in their use of client facing and back-office AI-based solutions. Regulatory, privacy, ethical, IP, and cyber considerations underscore that technical efficacy is only part of the equation. Due diligence, monitoring, and compliance also weigh just as heavily, as the repercussions for getting it wrong can result in potential exposure that could outweigh the savings associated with the purported efficiency gains. With that, the CLO must support a delicate balance between buttressing ingenuity while aiding in defining reasonable guardrails.
The survey findings also support that generative AI is being used to augment legal services at this stage vs. replacing legal personnel. Use cases that seem to be more readily adopted involve quicker research and intelligence. For instance, due diligence activities, accelerating review, and developing first drafts are scenarios that assist vs. replacing legal resources. AI is being used as a tool to improve the velocity of transactions by highlighting areas for review. Legal judgment is still critical to reviewing any byproduct and work product produced at this stage, but the trend is moving towards legal staff managing AI as a resource requiring supervision and quality control, rather than AI providing authoritative output.”
What this means for European legal departments
For corporate legal teams in Europe, the findings highlight several practical implications.
Legal departments must build stronger regulatory monitoring capabilities, particularly around AI and digital legislation. They must also develop internal technology literacy and rethink how legal services are delivered to the business.
Most importantly, CLOs are expected to operate as business leaders, not only as legal specialists. Their success depends on balancing risk management with strategic growth while navigating limited resources and increasing complexity.
The European data confirms that the CLO role is no longer defined by legal expertise alone. It is shaped by the ability to guide organizations through uncertainty with clarity, agility, and technological awareness.
