Rhode Island: AI Ethics Guidance for Law Firms

Bottom line for a Rhode Island firm: The Supreme Court acted on June 17, 2026, and the order does two distinct things. It amended Rule 1.1 Comment [6] to add the technology-competence duty, which is binding. And it adopted Interim Guidelines on the ethical use of generative AI, one set for lawyers and one for judicial officers, which by their own terms “neither amend Article V… nor carry the force of law.” So Rhode Island now has a binding competence hook plus advisory guidance, not a disclosure mandate. Notably, the Guidelines take the position that Rule 1.4 does not obligate lawyers to tell clients every time they use a GAI tool, though they say a lawyer must disclose GAI use when a client asks or when client information is entered into a GAI system. ABA Formal Opinion 512 remains the national baseline.

Start with: a written AI use policy, a citation verification protocol, and a named owner for aligning the policy to the June 2026 order and monitoring the CAIC for further amendments.

The June 2026 Supreme Court order

Citation: In re Amendments to Article V, Rule 1.1 of the Supreme Court Rules (Professional Conduct) and Adoption of Interim Generative AI Guidelines (R.I. June 17, 2026) (Suttell, C.J., Robinson, Lynch Prata, and Long, JJ.). Primary source PDF. See the tracker entry.

Binding half. Rule 1.1 Comment [6] now states that “a lawyer should keep abreast of changes in the law and its practice, including the benefits and risks associated with existing and developing technology.” That adapts the ABA Model Rule 1.1 Comment [8] technology-competence language (which refers to “relevant technology”), which Rhode Island had not previously adopted, and it gives the competence duty an explicit technology anchor.

Advisory half. The two sets of Interim Guidelines are explicit about their own status: they “neither amend Article V (Rules of Professional Conduct) and Article VI (Code of Judicial Conduct) of the Supreme Court Rules nor carry the force of law.” Their substance tracks the mainstream: Rule 3.3 requires critical review and verification before filing; Rule 1.5 permits an hourly bill to reflect only the actual time spent (the Guidelines’ example: a task GAI shortens from two hours to one bills as one hour) and asks that fixed or contingent fees still reflect the value of the work provided; Rule 1.6 directs lawyers to read each tool’s terms of use and privacy policy. The lawyer Guidelines are also posted as a standalone document.

The Rule 1.4 position is the one most worth reading closely. The Guidelines state that Rule 1.4 does not “affirmatively obligate lawyers to inform their clients every time they utilize GAI tools.” They draw two limits. A lawyer “must certainly disclose the use of GAI when a client asks, or when he or she enters client information into a GAI system,” citing Rule 1.6. And lawyers who have integrated GAI tools into their everyday practice “should consider disclosing such use to clients in a retainer or engagement agreement at the outset of the representation.” A firm operating across state lines should not generalize that position outward, and because it sits in guidance rather than rule text it could shift.

No operative bar opinion (pending activity)

The Rhode Island Supreme Court’s Ethics Advisory Panel has issued no opinion specifically addressing AI; its subject index (revised September 10, 2026) lists no AI topic. The Guidelines direct lawyers with specific GAI questions to request an advisory opinion from the Panel. In late 2024, the Rhode Island Bar Association president published Navigating the Era of Artificial Intelligence in Law. The President’s Message surveys “nine significant Ethics opinions on generative artificial intelligence” from the ABA and other bar bodies and identifies the Rhode Island Rules of Professional Conduct they implicate. It is not a formal ethics opinion and carries no binding disciplinary weight. Substantive activity now lives at the CAIC, covered in Section 6 below.

What federal courts in Rhode Island require for AI use in filings

The U.S. District Court for the District of Rhode Island has not issued a district-wide standing order or local rule requiring disclosure of AI use in court filings. As of September 2026, the court’s general orders, notices, and local rules contain no AI provision. Attorneys appearing before D.R.I. judges should still check for case management orders at the opening of each matter. The operative federal default is Fed. R. Civ. P. 11.

What Rhode Island state courts require for AI use in filings

As of September 2026, no standing order, local rule, or administrative order from the Rhode Island Supreme Court, Superior Court, District Court, or any other state court division requires attorneys to disclose AI use in court filings. The Supreme Court’s 2026-06-17 order did not add one: the Interim Guidelines address lawyer conduct and client communication, not disclosure to the court. The CAIC’s charge includes court rules and procedures.

What AI-related rules are pending in Rhode Island?

Committee on Artificial Intelligence and the Courts (CAIC)

The Rhode Island Supreme Court established the CAIC by Executive Order 2024-03, entered by Chief Justice Paul A. Suttell on 2024-10-22 (press release). The committee’s mandate is to examine the impact of AI on the practice of law, the administration of justice, access-to-justice issues, and court rules and procedures, and to recommend action to the Chief Justice. The CAIC operates through four subcommittees: professional conduct, judicial conduct, criminal law and evidence, and civil law and evidence. Steering Committee co-chairs are Associate Justice Erin Lynch Prata (Rhode Island Supreme Court) and Associate Justice Brian P. Stern (Rhode Island Superior Court).

Issued 2025-09-03, Executive Order 2025-06 extended the CAIC’s work and called for a written progress report to the Chief Justice by 2026-02-27. Executive Order 2026-07, entered 2026-05-12, continues the CAIC’s work and sets a new progress-report deadline of 2026-12-31. No CAIC progress report has been made public. The professional conduct subcommittee is the body most likely to produce rule amendments affecting daily practice; firms should monitor its output closely through the remainder of 2026.

S0627 (2025): Artificial Intelligence Act

Introduced 2025-03-07, Senate Bill S0627 was held for further study by committee on 2025-05-12 and was not enacted. Had it passed, it would have applied to developers, integrators, and deployers of “high-risk artificial intelligence systems” used in consequential decisions affecting employment, education, lending, housing, healthcare, and legal services. Enforcement would have been vested exclusively in the Rhode Island Attorney General. Legal services were explicitly within scope; a firm using AI for client intake, matter risk assessment, or conflicts screening could have qualified as a deployer. If a successor bill is introduced, firms should monitor the scope definitions carefully.

Governor’s AI Action Plan

Governor Dan McKee’s statewide AI Task Force, established by Executive Order 24-06 in February 2024, released a 75-page AI Action Plan in January 2026. The plan covers government, education, health care, finance, small business, and manufacturing, and centers on adoption rather than new regulation. It does not address attorney ethics, legal AI, or bar regulation. It is relevant context for understanding Rhode Island’s general regulatory posture as permissive and adoption-focused.

How do malpractice carriers in Rhode Island treat AI use?

No Rhode Island-specific carrier guidance on AI has been identified. Rhode Island law firms are primarily served by national carriers; ALPS explicitly serves Rhode Island law firms. In its published analysis Insurance Coverage Issues for Lawyers in the Era of Generative AI, ALPS flags three exposures most likely to interact with coverage exclusions. Those three are: blind reliance on AI output, client-facing AI without attorney supervision, and data breaches via AI platforms. Broker commentary reports LPL underwriters focusing on firms’ AI controls, though most LPL applications reviewed for this site do not yet ask about AI.

What does my Rhode Island malpractice carrier ask about AI at renewal?

ALPS, the dominant carrier for Rhode Island firms in this segment, has published its substantive AI risk position but has not published a Rhode Island-specific renewal-application module. ALPS’s published guidance points to ABA Formal Opinion 512 (2024-07-29) as the substantive standard, with attention to confidentiality, supervision, and citation verification. Firms should be ready to produce a written AI use policy, a citation verification protocol, vendor diligence records, and training records.

The state-specific trigger has now fired. The Supreme Court’s 2026-06-17 order amended Rule 1.1 Comment [6] to add the technology-competence duty and adopted Interim Guidelines for lawyers, so documentation should map to those rather than to the pre-order posture. Note what the Guidelines do not require: they state that Rule 1.4 does not obligate lawyers to inform clients every time a GAI tool is used, so a consent-on-every-use process is not what this jurisdiction asks for.

What documentation should a Rhode Island firm keep on file?

Month one (foundational)

1. (Owner: managing partner + firm administrator) Written AI use policy covering approved tools, what client information may or may not be input, review and verification procedures, and supervision protocols. Anchored in RPC 1.1, 1.6, 5.1, and 5.3 as identified in the bar president’s message.
2. (Owner: litigation lead) Citation and quotation verification protocol confirming that every AI-generated citation, quotation, and legal proposition is verified against the primary source before any court filing. Anchored in RPC 3.3 and 8.4; D.R.I. has no standing order, but surrounding jurisdictions have seen sanctions.
3. (Owner: firm administrator) Staff training records documenting that attorneys and legal staff have reviewed AI tool capabilities and limitations, the firm’s AI policy, and RPC 1.1, 1.6, 5.1, 5.3, and 3.3. Required by implication of RPC 5.1 and 5.3.

Months two and three (operational documentation)

1. (Owner: firm administrator + outside IT) Vendor due diligence record for each approved AI tool: terms of service review, data retention and deletion policy, whether the tool trains on user inputs, security certifications, and any data processing agreement. Anchored in RPC 1.6 and ABA Formal Opinion 512.
2. (Owner: managing partner + billing partner) Engagement letter provisions addressing AI use in the representation: which tools may be used, what data may be processed, what confidentiality protections are in place, and consent for third-party tools that will process confidential information. ABA Formal Opinion 512 warns that boilerplate consent is insufficient for self-learning tools.

Months four to six (per-matter discipline)

These are recurring practices, not one-time projects: each new matter exercises them.

1. (Owner: matter lead attorney) Client confidentiality consent where confidential information will be input into a third-party AI tool, recorded in the matter file. Anchored in RPC 1.6.
2. (Owner: managing partner) Alignment to the June 2026 order, then continued CAIC monitoring. The Supreme Court has now acted: Rule 1.1 Comment [6] carries the technology-competence duty and two sets of Interim Guidelines are in place. Refresh the firm’s AI policy against those, keeping the binding amendment and the advisory Guidelines distinct. The CAIC’s professional conduct subcommittee remains the body most likely to produce further rule amendments, so keep a designated owner monitoring it.

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