Flank
Flank deploys supervised AI agents that take over high-volume legal work for enterprise in-house teams: triaging requests from the business, drafting NDAs, statements of work and other documents from the team's own templates, reviewing and redlining vendor paper and data processing agreements against the team's playbook, running negotiation rounds, answering recurring legal and compliance questions from other departments, and completing information security questionnaires. Requests arrive through the channels the business already uses, principally Outlook, Teams, Slack and an intranet portal, so business users never open a new tool; the agent identifies the request type, pulls the relevant context and works against the templates, terms and escalation rules the legal team has set. The legal team decides which tasks agents handle, sets approval thresholds by matter type, counterparty and risk, and reviews finished work in a supervision queue that shows flagged items with the agent's reasoning, with every decision, edit and negotiation point logged and every correction fed back into the agent. Complex or high-risk requests are escalated rather than completed. Flank Record, added in 2026, captures every executed contract at signature, extracts key terms and keeps a supervised record of the contract estate that can be queried in plain language. The company is Legal OS GmbH, trading as Flank, based in Berlin; it names Simmons & Simmons, Axel Springer, Financial Times, Bolt, DeepL, Accor and Perk as customers and partners, and describes its buyers as enterprises, banks and governments. Underlying models come from OpenAI, Anthropic and Google, run through Google Cloud and Azure in a dedicated tenant per customer in the customer's chosen region, with zero-retention terms in place with the model providers.
Capability grades
All 15 axes, graded from public sources on the date shown. Hover a grade to see what the letter means on that axis.
AI Centrality
How much of the product is actually AI. Whether the machine learning is the mechanism the buyer is paying for or a feature layered onto conventional software, and whether the vendor is specific about which is which.
The agents are the product. Every function the home page sells, intake and routing, drafting, redlining, negotiation rounds, question answering and the Flank Record contract estate, is described as agent execution against the customer's templates and playbooks, and the vendor's own framing distinguishes itself from assistants and Word plug-ins on exactly that ground: tools make lawyers faster, Flank delivers the outcome. Remove the models and there is no workflow system, document repository or template library left to sell; Flank Record is itself maintained by agents rather than being a CLM the agents sit on. The company's origin as Legal OS is recorded in the privacy policy as the legal entity name only, and nothing on the current estate describes a pre-model product surviving underneath.
Citation Accuracy and Hallucination Disclosure
Whether the vendor publishes measured accuracy on citations and assertions, grounds output to primary sources, and says plainly what its system does when it does not know. Legal has a documented public record of fabricated citations reaching filed briefs, so an untested claim of accuracy is not evidence.
Accuracy is asserted without measurement. The FAQ answers the question whether output can be trusted with a yes and then describes the mechanism, that every agent is trained by the customer's team on its own knowledge and preferences and that every interaction can be tracked for accuracy and improvement, and the home page says every output is grounded in how the team actually works rather than in generic legal reasoning. No accuracy figure, test set, error rate or evaluation is published anywhere located. Two limbs of the band do not apply to this product and are not held against it: the agents draft and review contracts against customer templates and playbooks rather than retrieving primary law, so grounding to primary authority and citation status checking are not functions the product performs. What the band does ask of a contract agent, a measured statement of how often its redlines or drafts are wrong, is not published. Home page, FAQ, use cases page and the vendor's insights hub checked 6 September 2026.
Autonomy and Oversight Model
What the system decides on its own, what a lawyer must approve, and whether the vendor documents where the review point sits. A tool that drafts under review and a tool that files without one are different products and different risks.
All four limbs are published on the home page and its FAQ. Modes: the legal team chooses which tasks agents handle and whether a given class runs unattended or lands in review, and the vendor states plainly that complex or high-risk requests are escalated while everything else is handled. Constraints: approval thresholds are set by matter type, counterparty and risk, alongside escalation rules and risk tolerances, and agents request approval when the rules require it. Review surface: supervised requests land in a supervision queue with flagged items and the agent's reasoning, where a lawyer approves, adjusts or escalates, and the customer chooses who sits behind the queue. Route back: every decision, edit and negotiation point is logged, corrections feed back into the agent so that Tuesday's fix improves Wednesday's output, and the FAQ states the customer's team retains final authority for outcomes. The threshold at which the system acts alone is therefore a customer setting rather than a vendor default, and the vendor says so. Home page, product FAQ and use cases page read 6 September 2026.
Operational and Outcome Evidence
Named, dated evidence that the product works in production at real firms or legal departments. Case studies with figures and identified customers count. Unattributed testimonials and launch announcements do not.
Named customers without figures, and figures without named customers, which is the B shape exactly. Simmons & Simmons is named with a quote attributed to a partner, Lucy Shurwood, stating that agents autonomously handle drafting, review and negotiation of NDAs, DPAs, service agreements and IMAs and are live for the firm's teams and clients, linked to the firm's own partnership announcement; Perk is named with a quote attributed by first name only. Axel Springer, Financial Times, Bolt, DeepL and Accor appear as logos with no attached statement. The figures sit elsewhere and unattributed: the use cases page states five minutes of legal time instead of forty-five on an NDA and a sixty per cent cut in outside counsel spend from keeping routine work in-house, with no customer, date or method attached to either. Nothing joins a named customer to a measured change. Home page, use cases page and the Simmons & Simmons partnership link checked 6 September 2026.
Privilege and Confidentiality Posture
How client confidences are handled: attorney client privilege and work product treatment, segregation of one client matter from another, whether client data trains any model, and what the vendor commits to in writing rather than in marketing.
Four of the five limbs are met in writing a buyer can read before signing, and the fifth is absent. No training on client data is stated on the home page and the security page. Segregation is documented at the level an in-house buyer requires: a dedicated tenant for every customer, on GCP or Azure, in the customer's chosen region, with role-based access and single sign-on. The position on third-party model providers is explicit and unusually complete, with OpenAI, Anthropic, Google Cloud and Azure OpenAI named in the DPA's sub-processor clause with executed standard contractual clauses recorded against three of them, and the security page stating zero data retention clauses with all LLM providers. Retention and deletion are stated in the DPA, deletion on termination and on instruction, though no retention period is given anywhere. What is missing is the limb this axis exists for: nothing on any surface addresses privilege or work product handling directly, for a product that drafts and negotiates on the customer's behalf. Under the standing reading of this band that limb is required for A and a strong confidentiality regime does not stand in for it. Home page, security page, trust centre, DPA and product privacy policy read 6 September 2026.
UPL and Professional Responsibility Posture
Whether the vendor is clear that it supplies a tool rather than legal advice, who its audience is, and how it addresses unauthorized practice of law, competence and supervision duties, and jurisdiction limits. ABA Formal Opinion 512 is the reference point.
The intended audience is clear and the advice line is not drawn. The estate addresses enterprise in-house legal teams throughout and describes the agents as working like paralegals under the team's supervision, and the FAQ states that the customer's team retains final authority for outcomes and that agents absorb repeatable work rather than replacing lawyers. Those are statements about supervision. What is absent is any position on advice versus tooling for the surface where it matters most: the agents answer recurring legal and compliance questions directly to HR, procurement and other business teams through email and chat, and nothing located tells those users that an agent's answer is not legal advice or is subject to lawyer review, nor names any jurisdiction limit, although the insights hub describes agents applying jurisdiction-specific clauses. No terms of service or acceptable use policy is published in which a disclaimer could sit. Home page, FAQ, use cases, insights hub, DPA and both privacy policies checked 6 September 2026; no ethics or disclaimer page exists in the site inventory.
AI Governance and Bias Disclosure
Published governance over model behaviour: who owns it inside the vendor, what is tested before release, and what is disclosed about disparate output across matter types, parties, or populations.
A published, independently audited governance framework short of testing results or a named owner, which is the B band and the same position the index records for Corlytics and Ontra. The trust centre carries an ISO 42001 certification with certificate number AIMS-LE-103025 and an A-LIGN badge, stated to cover the organisation and described as an artificial intelligence management system governing legal, safety and fairness considerations in the development and deployment of the AI features. A document titled How Flank uses LLMs FAQ, described as covering data handling, prompt-injection controls, training assurances and ethical usage guidelines, exists on the trust centre behind an access request and was not requested. No accountable owner is named, no pre-release testing regime is described, and nothing is published about uneven output across contract types, counterparties or business users. Trust centre and security page read 6 September 2026.
AI Safety and Data Stewardship
Retention, deletion, access control, and what happens to prompts and documents after they are processed. Whether the vendor states its subprocessors and its incident practice, or leaves the buyer to assume.
Four of the five limbs are published with the specificity the A band asks for, and retention is the one that falls short. Deletion: the DPA commits to secure deletion after termination absent a retention obligation, to correction or deletion on the customer's instruction, and to surrender or deletion on request. Access control: least-privilege access to customer data, restricted production access, unique IDs and periodic access reviews are listed as live controls on the Secureframe-monitored trust centre, with encryption at rest and in transit. Sub-processors: six named in DPA clause 9.3 with locations and, for Azure OpenAI, eight named regions, with written notice before any change and a two-week objection window. Incident practice: DPA clause 10 commits to written notification within 24 hours of a personal data breach with the categories, approximate numbers and mitigation described. Retention: the product privacy policy of 17 March 2026 states data is kept only as long as necessary and names no period, and its own update banner claims that revision added specific data retention periods, which the document does not contain. The home page's zero data retention claim is resolved by the security page as zero-retention clauses with the LLM providers, not a statement about Flank's own storage, and Flank Record is retention by design. DPA, product privacy policy, security page and trust centre read 6 September 2026.
AI Liability and Recourse
What the vendor stands behind contractually when its output is wrong. Indemnities, caps, carve outs, insurance, and whether any of it is published or only reachable through a negotiated agreement.
Nothing published on who bears the loss when an agent's draft, redline or negotiation position is wrong. The principal customer agreement, which the DPA refers to as the Agreement between the Customer and Flank, is not published on any surface, and the site footer's legal set is the DPA, an Impressum and two privacy policies; no terms of service, master subscription agreement or acceptable use policy exists in the page inventory. The DPA itself carries no indemnity, liability cap, warranty on output or insurance position, its obligations running to data protection alone. The trust centre lists cyber insurance as a procured control, which concerns the vendor's own loss rather than any recourse a customer can invoke. The exposure is concrete for this product, since agents send finished NDAs and negotiated positions to counterparties under the customer's supervision rules, and nothing states whether Flank stands behind an agent acting within the thresholds the customer set. Home page, footer inventory, DPA, both privacy policies and trust centre checked 6 September 2026; the unpublished principal agreement is the rebuttal route.
Practice Systems Integration Depth
How deeply the product reaches into the systems legal work already lives in: document management such as iManage and NetDocuments, Word and Outlook, contract lifecycle management, matter management, e-billing, and court filing systems.
Named integrations with the delivery mechanism described, short of what each connection moves. The home page names Outlook, Teams, Slack, Jira, Salesforce and CLMs generically, and states that requests arrive through the customer's existing Outlook inbox or intranet portal and that agents work where the business already works without custom integration projects; the FAQ adds custom URLs and the legal systems the customer already uses, and says many deployments start without bespoke integrations with deeper connections following. Flank Record captures executed contracts at signature, which implies a signature-tool connection that is not named. The email channel is described well enough to understand, since the agent reads the inbox, identifies the request and replies with the draft attached. No documentation, help centre or developer index was located describing what syncs with a CLM or Salesforce, in which direction, or what a customer must configure; the Implementation page in the product navigation was not opened. Home page, FAQ and use cases page checked 6 September 2026.
Deployment Model and Data Residency
Where the software runs and where the data sits. Multi tenant cloud, single tenant, private deployment, on premises, and whether region of residence is a published option or an enterprise conversation.
Tenancy, region and the processing location as distinct from storage are all published. The security page states that customer data is contained within the customer's chosen region in a dedicated tenant on GCP or Azure, and the home page repeats dedicated regional tenants for every customer. DPA clause 8.1 forbids the processor and its sub-processors from transferring or processing personal data outside the EEA and UK without the controller's prior written consent, with the transfer mechanism to be identified and any change notified. Clause 9.3 separates hosting from model processing explicitly: Google Cloud Platform is listed as EU for hosting and global for LLMs, MongoDB as EU, and Azure OpenAI services with eight named regions, Amsterdam, Canada East, East US 2, Japan East, France Central, Sweden Central, Switzerland North and UK South, with OpenAI and Anthropic in the USA under executed standard contractual clauses. That is the where-processing-happens limb stated in terms. No tiers are published, so the what-changes-between-tiers limb has nothing to bite on and is not held against the record. Security page, home page and DPA read 6 September 2026.
Security Certifications and Trust Center
Independent attestation a buyer can pull without a sales call: SOC 2, ISO 27001, penetration test summaries, a trust center with current reports and named scope rather than a badge image.
Certification is real and stated, and the evidence sits behind a request whose access tier the portal does not state. The Secureframe-hosted trust centre at trust.flank.ai renders fully and carries SOC 2 Type 2, ISO 42001 with certificate number AIMS-LE-103025 and an A-LIGN badge, GDPR and CCPA, together with a live control monitor listing an annual third-party penetration test, encryption at rest, cyber insurance and vendor SOC 2 reviews. The SOC 2 Type 2 report and the ISO 42001 certificate are each behind a Request button, and a Request all documents control covers the set; nothing on the page states whether the request fulfils on an email address or an NDA click-through or routes to a sales conversation, and no request was submitted. No SOC 2 coverage period, scope or auditor is stated on the open page. Under the standing rule for an unstated access tier the lower tier is graded and this note says why: a named standard with a route to the report, short of dates, scope and evidence reachable without asking. Trust centre and security page read 6 September 2026.
Model Supply Chain Disclosure
Which models sit underneath, whose they are, where they run, and whether the vendor commits to telling customers when that changes. A legal buyer inherits every dependency it cannot see.
Providers, locations and change notice are all published; the models themselves are not named, which holds this at the top of B. DPA clause 9.3 names OpenAI and Anthropic as LLM providers in the USA under executed standard contractual clauses, Google Cloud Platform as global for LLMs, and Microsoft Azure OpenAI services across eight named regions; the trust centre repeats the same six sub-processors with Anthropic, OpenAI, Google Cloud and Azure each marked LLMs. Clause 9.2 commits to written notice with a reasonable period before any sub-processor is added or replaced, with a two-week objection window, and clause 12.4 adds notification by publication where the DPA is updated. The security page states zero data retention clauses with all LLM providers. What no surface states is which model from each provider runs which task, and under the standing reading of this band naming the provider does not satisfy the separate limb that the models underneath are named. DPA, trust centre and security page read 6 September 2026.
Commercial Transparency
Whether a buyer can learn what this costs without entering a sales process: published rates, the unit being charged, what sits behind an enterprise tier, and what implementation adds.
No pricing information is published at any level. No pricing page appears in the navigation or the footer, the FAQ does not address cost, and the only commercial call to action on the estate is a fifteen-minute demo booking. Nothing states the unit of charge, whether the product is priced per agent, per request, per seat or per workflow, and no tier names or feature splits are published from which the shape could be inferred. Home page, FAQ, use cases page, product navigation and footer checked 6 September 2026; the vendor's insights hub was searched and carries buyer guidance on pricing models generally without stating Flank's own.
Firm and Practice Coverage
Who the product is actually built for. AmLaw, midlaw, small firm and solo, in house departments, government and courts, and which practice areas are supported rather than merely claimed.
Segment and work type are described with substance, and the boundaries are left open. The buyer is stated as enterprise in-house legal, with the security page adding enterprises, banks and governments, and the customer list showing large corporates, a media group, a bank-adjacent fintech and one law firm, Simmons & Simmons, deploying agents for its own teams and clients. The work covered is stated concretely: NDAs, DPAs, service agreements, IMAs, statements of work, MSA redlines, procurement reviews, infosec questionnaires, employment questions from HR and legal FAQs from the business, with the FAQ naming NDAs and low-risk vendor documents as the usual first use case before expansion into sales and procurement playbooks. What is not stated is where the product stops: no practice area, contract type, jurisdiction or firm size is named as unsupported, and the escalation of complex or high-risk requests describes a control rather than a coverage limit. Home page, FAQ, use cases and security page checked 6 September 2026.
Legal Signals
What each signal meansA signal records what public sources say on the date shown. It is not a grade and it is not a recommendation. Where a signal reads Not addressed, it means the index did not locate the material in public sources on that date, which is a statement about disclosure rather than about the product.
Client Data in Training
Can material a lawyer puts into this product be used to train a model?
A public policy or trust page states no training on customer content, with no matching term located in the published agreement.
Public material states that customer data is never used for training, on the home page and the security page, and no matching term was located in the published agreement. The DPA, last updated March 2026, confines processing to the customer's documented instructions and prohibits staff from processing beyond them, which excludes training as a matter of construction but never names it; the product privacy policy's only improvement basis is anonymised usage data under legitimate interests, which is telemetry rather than customer content. The principal customer agreement the DPA refers to is not published, so a buyer cannot see whether the marketing commitment appears in it. A How Flank uses LLMs FAQ described as carrying training assurances sits on the trust centre behind an access request and was not requested. Surfaces checked 6 September 2026.
Prompt and Output Retention
How long does the product keep what a lawyer typed, and can that be set to zero?
Retention is acknowledged in public materials with no stated period.
Retention is acknowledged with no stated period. The product privacy policy of 17 March 2026 states data is retained only as long as necessary for its purposes or as required by law and then deleted or anonymised, with earlier deletion available on request under the DPA; the DPA commits to deletion after termination and on instruction. The home page's zero data retention claim is clarified on the security page as zero data retention clauses with all LLM providers, which is a provider-layer commitment rather than a statement of Flank's own retention, and Flank Record keeps an always-current record of every executed contract by design. The privacy policy's own update banner states the March 2026 revision added specific data retention periods, and section 7 of that document contains none. Surfaces checked 6 September 2026.
Ethical Walls and Matter Segregation
Does retrieval respect the firm’s ethical walls, or can the model read across them?
The product maintains its own permission model, documented, requiring the firm to keep it aligned.
The product maintains and documents its own separation model at the tenant level, which is the level an in-house buyer requires: the security page states customer data is contained in a dedicated tenant on GCP or Azure in the customer's chosen region, the home page lists role-based access, single sign-on with all major identity providers and audit logs as included controls, and the trust centre's live monitor lists least-privilege access to customer data. The customer keeps the role model aligned. Nothing addresses matter-level walls within a tenant, which the product's in-house buyer does not ordinarily need and which a law firm deploying it, as Simmons & Simmons does, would. Surfaces checked 6 September 2026.
Third Party Request and Subpoena Notice
If someone subpoenas the vendor for a firm’s data, does the firm hear about it first?
Terms commit to notice where lawfully permitted. No transparency report located.
The published DPA commits to notice in two places. Clause 12.1 requires Flank to inform the customer without undue delay if personal data is endangered by seizure or attachment or by other measures of third parties, and clause 3.1 requires it to inform the customer before any processing that national or European law obliges it to perform outside the customer's instructions, insofar as legally permissible. No transparency report is published. The product privacy policy runs the other way, stating only that data may be disclosed in response to valid requests from public authorities with no mention of notice, and under the standing rule the agreement governs over the policy. Surfaces checked 6 September 2026.
Primary Law Corpus Provenance
Where does the law in this product come from, and does the vendor have the right to use it?
No located public material identifies the corpus behind the product’s answers.
No located public material identifies a legal corpus behind the product's answers, and the product is not built on one: agents draft, review and answer against the customer's own templates, playbooks and policies, which the home page describes as grounding every output in how the team works rather than in generic legal reasoning. No primary law source, licence or update cadence is published. Home page, FAQ, product pages and insights hub checked 6 September 2026.
Good Law Verification
Does the product tell you when the authority it just cited has been overruled?
No located public material addresses whether authority is checked for subsequent history.
No located public material addresses whether authority is checked for subsequent history, and the product does not retrieve or cite primary law; its output is contract drafts, redlines, negotiation positions and answers to business teams from the customer's own material. Recorded as the honest value for a product with no citator function. Surfaces checked 6 September 2026.
Refusal and Uncertainty Behaviour
What does the product do when the answer is not in the corpus?
The vendor describes refusal or abstention behaviour in public materials.
An explicit path for not completing a request is described in public materials: the home page states that agents apply the customer's escalation rules, approval thresholds and risk tolerances and flag anything outside bounds, that complex or high-risk requests are escalated rather than handled, and that supervised requests land in a review queue with the flagged items and the agent's reasoning. The FAQ adds that agents request approval when rules require it. The behaviour is described rather than demonstrated, since no published evaluation or product recording shows the escalation firing, and nothing states what the agent does when the customer's playbook gives it no answer as distinct from when a rule tells it to stop. Surfaces checked 6 September 2026.
Fabricated Citation Record
Does a public court record exist involving output from this product?
No court order, opinion or disciplinary record naming this product has been located as of the date shown. This is a statement about the public record, not a finding about the product.
No court order, opinion or disciplinary record naming Flank or Legal OS GmbH was located as of 6 September 2026. The AI Hallucination Cases database maintained by Damien Charlotin was searched on the product name and the corporate name, together with a general search for court findings naming the product. This is a statement about the public record and not a finding about the product; the product drafts contracts rather than court filings, so the exposure this signal tracks is remote for it.
Bar Guidance Alignment
Has the vendor engaged in public with the ethics opinions its buyers are bound by?
No located public material engages with bar or ethics guidance.
No located public material engages with bar or ethics guidance. The estate makes no reference to any ethics opinion, bar rule or professional responsibility framework in any jurisdiction, and the vendor's professional-responsibility positioning is confined to statements that the customer's team retains final authority and that agents do not replace lawyers. The company is German and its named customers span the UK, Germany and the wider EU, so the reference points would differ from the ABA opinion this index uses as a baseline, but none of any jurisdiction is named. Home page, FAQ, insights hub, DPA and privacy policies checked 6 September 2026.
Billing and Fee Posture
Does the vendor address what happens to the bill when the work takes an hour instead of six?
Public materials claim time savings without addressing billing or disclosure, and the product sits inside a fee relationship between a lawyer and a client where those savings would change the bill.
Time and cost claims are published and nothing addresses the bill. The use cases page states five minutes of legal time instead of forty-five on an NDA and a sixty per cent cut in outside counsel spend from keeping routine work in-house, and the home page's proposition is that routine work leaves the desk and does not come back. No per-matter record of AI-assisted work framed for fee purposes is described, although every agent action is logged, and no guidance on fee or disclosure treatment is published. The primary buyer is an in-house team that bills no client, so the question lands obliquely there, but a law firm is a named customer: Simmons & Simmons states that agents are live and delivering for its teams and its clients, which places the product inside a lawyer-to-client fee relationship for that deployment, and nothing published addresses how that firm's clients are told or charged. Surfaces checked 6 September 2026.
Outside Counsel Guideline Readiness
Can a firm get this vendor through a client’s AI clause without a bespoke negotiation?
A subprocessor and model provider list plus client facing disclosure material is published or available without an agreement in place.
A current sub-processor and model provider list is published and the client-facing disclosure material is a published DPA, which together meet the top value. DPA clause 9.3 names Google Cloud Platform, MongoDB, Mailgun, Azure OpenAI services with eight regions, OpenAI and Anthropic, with executed standard contractual clauses recorded against three and a two-week objection window on changes; the trust centre repeats the same six with each LLM provider marked as such. The DPA is published in full without an agreement in place and is drafted to be forwarded, and the security page adds that zero data retention clauses are in place with all LLM providers. A firm can therefore tell a client which model providers see its content and on what transfer basis without a bespoke negotiation. Surfaces checked 6 September 2026.
Court Disclosure Support
If a judge’s standing order requires an AI disclosure, can the product produce one?
Some elements of the record are available, short of a document level export.
Some elements of a disclosure record are available and no document-level export is described. The home page states that every decision, edit and negotiation point is logged and that the supervision queue shows flagged items with the agent's reasoning, and the FAQ says every interaction can be tracked; that is a per-matter record of what the agent did and what a human approved. Nothing states that the record can be exported per document, and it does not cover the model used, since the models are not named anywhere on the estate. Court disclosure is remote for a contract agent and the vendor does not address it. Surfaces checked 6 September 2026.