June 1, 2026 (in 3 days): New York: 22 NYCRR Part 161 takes effect, system-wide AI policy for all UCS courts

AI Governance Quarterly Attestation

A short managing-partner sign-off, every quarter, that the firm's AI governance documentation set is current. Companion to the annual cadence in Policy Template, Section 15 and the renewal-time Audit Report.

An annual policy review is the floor; a quarterly attestation is what keeps the annual review honest. Four short quarterly attestations are easier to defend at renewal than one rushed year-end pass. The form below is a starting point; have a licensed attorney in your state confirm the language before adoption.
On this page
  1. Why quarterly
  2. Who signs
  3. The attestation form
  4. How to file

Why quarterly

ABA Formal Opinion 512 places supervisory responsibility for AI use on managerial lawyers under Rules 5.1 and 5.3. The Policy Template's Section 15 sets the review floor at "at least annually." The quarterly attestation is the cadence that lets a managing partner say, with documentation, that supervision was active during the year, not reconstructed at renewal.

The quarterly cadence also matches how malpractice carriers increasingly frame the underwriting conversation: not a single year-end snapshot, but a rolling record of governance activity. Four short signed attestations across the policy year produce a cleaner audit trail than one long memo at year end.

Who signs

  • Managing Partner as the signer of record under Rule 5.1.
  • AI Committee chair or designated partner, where the firm has assigned the AI program to a committee under Section 10 of the Policy Template, signing alongside or in lieu of the Managing Partner if the firm structure delegates the program.
  • Register custodian (typically the AI Committee chair or a designated administrator) co-signs item 5 below to confirm the usage register has been quarter-end reviewed.

The attestation form

The form below is the attestation itself. Print, complete, sign, and file with the firm's governance records. Each quarter is its own document; do not amend a prior quarter's attestation.

QUARTERLY GOVERNANCE ATTESTATION, AI USE PROGRAM

Firm: ____________________________________________

Quarter: Q____ ________ (e.g., Q2 2026)

Period covered: ____________________ to ____________________

As Managing Partner of the Firm, I attest that:

  1. The Firm's AI Use Policy in effect during the quarter is version __________, adopted __________, and is the current version on file.
  2. Section 12 training requirements are current. Training completion stands at _______ of _______ attorneys and _______ of _______ staff. Any gaps are identified, with completion target dates.
  3. Section 3's approved-tools list is current. Tools added or reclassified this quarter: ____________________________________________ . Vendor diligence files are complete for each Tier 1 and Tier 2 tool.
  4. Section 8 verification logs were filed for AI-assisted filings during the quarter. Coverage rate (verification logs filed / AI-assisted filings, from the usage register): _______ %. Any unverified filings are identified and remediated.
  5. The firm-wide Usage Register has been quarter-end reviewed by the register custodian. Total entries this quarter: _______ . Cross-checks for data classification mismatch (Confidential / Highly Sensitive in a Tier 2 or 3 tool) are clean, except as identified in item 6.
  6. Section 13 incidents during the quarter (closed / open): _______ / _______ . Each open incident has an assigned owner and target resolution date. Carrier notice obligations were assessed for each.
  7. Employee acknowledgments are current. Signed acknowledgments on file: _______ of _______ headcount. Onboardings this quarter: _______ , each with a current signed acknowledgment before tool access was provisioned.
  8. The next scheduled policy review under Section 15 is on ____________________ . No material changes to rules of professional conduct, state-bar guidance, or the Firm's practice areas have arisen this quarter that require an out-of-cycle revision, except as identified in item 9.
  9. Open items requiring action before the next attestation: ____________________________________________________________________________________________ .

Signed by:

Managing Partner signature: ____________________________________________

Print name: ____________________________________________

Date: ____________________________

Co-signed by Register Custodian (item 5):

Signature: ____________________________________________

Print name and title: ____________________________________________

Date: ____________________________

How to file

  1. One per quarter, four per year. The attestations stack into a rolling 12-month record. Skipping a quarter leaves a visible gap in the record; better to file an attestation that flags an open item than to skip and reconstruct.
  2. File with the firm's governance records. Filed alongside the policy, the vendor diligence files, and the rolling acknowledgment roster, not in a partner's individual files.
  3. Cross-link to the audit report. The most recent four attestations are an input to the renewal-time Audit Report's "quarterly attestations signed" line. Each is a separate document in the file; the audit report is the cover.
  4. Treat open items as commitments. An attestation that lists an open item without a target date is not credible at audit. Items 4, 6, and 9 should always have explicit dates if non-zero.
  5. Retain through the malpractice tail. Quarterly attestations are responsive to a malpractice claim or coverage dispute. Retain at least as long as the longest matter file in the period covered plus any open extended-reporting period.

Attestation mapped to Policy Template Section 15 and ABA Formal Opinion 512 (July 2024). Last verified 2026-04-29.