--- title: "Client-facing & access-to-justice AI tools" url: "https://ailawframework.com/obligations/client-facing-and-access-to-justice-ai-tools" type: "obligation" site: "AI Law Framework" id: "A43" task_count: 5 last_reviewed: "2026-09-23" --- # Client-facing & access-to-justice AI tools > Define the service boundary, supervision and escalation route before publishing a client-facing tool. Check its outputs, data handling and accessibility against the actual users and intended purpose. Canonical page: https://ailawframework.com/obligations/client-facing-and-access-to-justice-ai-tools Last reviewed: 2026-09-23 Site index for agents: https://ailawframework.com/llms.txt Intake bots, document-assembly portals and access-to-justice chatbots that give anything resembling legal (or migration) advice without real-time supervision by an admitted practitioner risk unqualified/unregistered legal practice. A disclaimer does not cure it. ## Key facts - Tasks: 5 - Green: 0, Yellow: 4, Red: 1 - Levels: Green is AI drafts and the lawyer checks; Yellow is lawyer and AI draft together; Red is the lawyer writes and AI may only check, clarify or collect data. ## Principles - **Define the matter**: Confirm the client’s instructions, jurisdiction, intended output and the information available before dividing the work. - **Protect the information**: Confirm that the actual tool, feature and processing terms permit use of this information, including access, retention, training and disclosure conditions. - **Confirm the source material**: Check the work against the original records and identify omissions, contradictions and unresolved information. ## Checklist - Confirm that the actual tool, feature and processing terms permit use of this information, including access, retention, training and disclosure conditions. - Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use. ## Restrictions - Confirm firm, client and applicable court or professional restrictions before using any AI feature. ## Jurisdiction note Apply this guidance to the actual matter and jurisdiction. Confirm current requirements before relying on an example. ## Basis Practice guidance supports planning; the responsible lawyer confirms the scope, evidence and review requirements for the matter. Intake bots, document-assembly portals and access-to-justice chatbots that give anything resembling legal (or migration) advice without real-time supervision by an admitted practitioner risk unqualified/unregistered legal practice. A disclaimer does not cure it. ## Limits on AI assistance Red lines — never in this area ## Limits on AI assistance No public-facing AI giving tailored legal or migration advice without real-time admitted-practitioner supervision (Migration Act s 280; general prohibition on unqualified practice). No collection of a user's confidential information into a non-compliant tool. Accessibility and bias of the tool assessed before launch. - No public-facing AI giving tailored legal or migration advice without real-time admitted-practitioner supervision (Migration Act s 280; general prohibition on unqualified practice). - No collection of a user's confidential information into a non-compliant tool. - Accessibility and bias of the tool assessed before launch. ## Review checklist The lawyer's review checklist ## Review checklist Supervision model documented Scope limited to information, not tailored advice Data-handling & privacy notice in place Bias/accessibility assessment completed - Supervision model documented - Scope limited to information, not tailored advice - Data-handling & privacy notice in place - Bias/accessibility assessment completed ## Tasks (5) | Task | Level | How AI is used | What the lawyer must review | | --- | --- | --- | --- | | [Review a client-facing chatbot or intake script against the no-advice line](https://ailawframework.com/obligations/client-facing-and-access-to-justice-ai-tools/review-a-client-facing-chatbot-or-intake-script-against-the-no-advice-li.md) | Red | From the script and sample transcripts, list answers that look like tailored advice, missing escalations and data-handling gaps. | Have an admitted practitioner own the advice layer Approve scope, disclaimers, escalation and data handling before launch Re-approve them after every material… | | Review public self-help content for accuracy and the advice line | Yellow | Compare the draft page to the current sources the lawyer has named, list stale statements and flag wording that reads as tailored advice. | Check the content is current Check it does not become personal advice: public content is still the firm's | | Build an escalation matrix for a client-facing tool | Yellow | From the tool flows, list question types, the point a human must take over, and the record that must be kept. | Confirm the escalation roster is real Do not launch a tool that cannot escalate | | Draft client-facing disclosures that the firm uses AI on the matter | Yellow | Produce first-draft retainer and website language from the professional-guidance headings the lawyer has listed, limited to how this firm actually uses tools. | Confirm the current professional rule on disclosure to clients Do not claim a review that does not happen | | Test a sample of chatbot transcripts for confidential data and wrong law | Yellow | From a permitted sample, list transcripts that include identifying facts, hallucinated rules or missed escalations. | Spot-check every flagged transcript Keep supervising: a clean sample is not a licence to stop | ## Jurisdiction notes ### New Zealand #### Responsibility The Law Society lists client-facing chatbots as a use and a risk. You remain responsible for the legal service. #### Client care Say who will do the work and how (r 3.5). Consult the client on steps to carry out instructions (r 7.1). #### Privacy Plain-language transparency, particular care with children and human review before acting. Do not test a chatbot on client or personal information. - Do not put a client-facing tool live on personal information without a privacy impact assessment and a human review step. Sources: - [NZLS: Generative AI guidance for lawyers (March 2024)](https://www.lawsociety.org.nz/professional-practice/rules-and-maintaining-professional-standards/generative-ai-guidance-for-lawyers/) (checked 2026-09-23) - [Lawyers and Conveyancers Act (Lawyers: Conduct and Client Care) Rules 2008](https://www.legislation.govt.nz/secondary-legislation/pco-drafted/2008/214/en/latest/) (checked 2026-09-23) - [OPC: Generative artificial intelligence (15 June 2023)](https://www.privacy.org.nz/resources-and-learning/a-z-topics/ai/generative-artificial-intelligence/) (checked 2026-09-23) - [OPC: Artificial Intelligence and the Information Privacy Principles](https://www.privacy.org.nz/resources-and-learning/a-z-topics/ai/) (checked 2026-09-23) ### United States Local name: Client-facing and access-to-justice AI tools #### Ethics Formal Opinion 512 and Florida 24-1 treat public chatbots as advertising, confidentiality and unauthorised-practice risks. NYC Bar 2024-5 flags advertising and discrimination. #### Agentic systems California's 2026 guidance: no agentic legal advice or representative acts without meaningful lawyer supervision. #### Colorado HB26-1263 (signed 1 July 2026, in force 1 January 2027): chatbot outputs must not be represented as equivalent to licensed professional services. - Do not let a client-facing tool give legal advice, open a solicitor-client relationship, or file anything without a lawyer in the loop. Sources: - [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-09-23) - [Florida Bar Ethics Opinion 24-1](https://www.floridabar.org/etopinions/opinion-24-1/) (checked 2026-09-23) - [State Bar of California, Practical Guidance for the Use of Generative Artificial Intelligence in the Practice of Law (2026)](https://www.calbar.ca.gov/Portals/0/documents/ethics/Generative-AI-Practical-Guidance.pdf) (checked 2026-09-23) - [Colorado Attorney General: Automated Decision-Making Technology and Chatbot Safety rulemaking](https://coag.gov/ai/) (checked 2026-09-23) - [New York City Bar Formal Opinion 2024-5: Generative AI in the Practice of Law](https://www.nycbar.org/reports/formal-opinion-2024-5-generative-ai-in-the-practice-of-law/) (checked 2026-09-23) *Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*