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Thirdfort

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 AI is real and vendor-claimed but it powers one product of five. Thirdfort sells identity verification, document verification, PEPs and sanctions screening, source of funds and know-your-business checks. Only document verification carries an AI claim, and it carries a clear one: a section headed An AI for detail, stating that artificial intelligence inspects every upload for signs of tampering, forgery and counterfeiting across visual, data and metadata elements, repeated in the FAQ in the first person as our AI. The flagship identity check makes no AI claim at all: its published mechanisms are cryptographic reading of the signing keys in an e-passport NFC chip and address matching against Experian data. The remaining products are screening and registry lookups against ComplyAdvantage, Dun and Bradstreet and Kyckr sources. Remove the models and four of the five checks are unaffected while document verification loses its detection engine. That restraint is itself evidence the claim is meant literally rather than decoratively, but it places the machine learning as a component of one module rather than the mechanism a buyer is paying for across the platform. Checked 7 September 2026.

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.

Grounding is real, documented and unusually verifiable, and there is a contractual accuracy undertaking, but nothing measures the result. Every identity document is cross-referenced against the Metropolitan Police's Amberhill database of documents reported lost or stolen, which is an external authoritative check a buyer can name. The identity check validates the cryptographic signing keys inside an e-passport chip rather than inferring from an image. Reference data is attributed to named suppliers with published terms. Clause 6.1(b) of the Terms of Use commits Thirdfort to use all commercially reasonable endeavours to ensure Reports are in all material respects accurate and complete, which is more than most records on this axis carry, and the app applies documented guardrails that block blurry, cropped or oversized uploads before they reach the model. What is absent is measurement. For a forgery detection product the natural figures are a detection rate and a false positive rate, and neither is published, nor a test set, an evaluation, or any named failure mode. One tension belongs on the record: Thirdfort warrants report accuracy in its own terms while the supplier terms it passes through disclaim it, with Experian stating it cannot accept liability for any failure of its services to achieve a particular result and Kyckr disclaiming any warranty of accuracy, completeness or reliability. Grounding to primary legal authority does not bite on a due diligence product and is counted neither way. Checked 7 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.

The route back to human judgement is contractual rather than advisory, which is rare on this axis. Clause 8 states that the Reports must not be relied on as the sole basis to make business decisions, that the firm is solely responsible for the conclusions drawn from them, and that Thirdfort provides no opinion and makes no recommendation on the treatment of results. The flow-down terms repeat it at supplier level, with ComplyAdvantage stipulating that results must not be used to draw any automatic conclusion or be relied on in isolation about any person flagged or not flagged. There is a review surface behind the words: the report presents flags in three states, showing what has passed, what is not relevant and what requires consideration, and the last of those is an explicit routing of the decision to a person. The uploaded document is stored alongside the report so the reviewer can check the model's input against its output. What is missing is the internal control structure. No threshold is published at which the system flags rather than passes, no confidence signal is described as visible to the reviewer, and nothing states what happens when a forgery is missed or a genuine document is wrongly flagged. Checked 7 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.

Real deployment evidence at scale, short of assessable measurement. The published base is more than 1,500 regulated businesses, and named customers appear with attributed quotations rather than logos alone: Boyce Hatton on meeting HM Land Registry's Digital ID Standard, Thomas Legal on client completion times as a competitive differentiator, Mezzle on the client experience, and Direction Law, which states it set a target of a 50 per cent increase in the speed of its compliance process and believes it not only hit but exceeded it. Operational figures are published and specific: 75 per cent of individuals complete their checks within 24 hours, documents verified from 195 jurisdictions, electronic address verification across 17 jurisdictions, and reports returned in minutes. Two things hold this at B. The figures carry no method, sample, baseline or date, and the strongest of them is a customer's own belief about its target rather than a measured result. And none of the outcome evidence is attributed to the AI: the completion and speed claims describe the app and the check workflow, so a buyer assessing the forgery detection specifically has adoption evidence for the platform and none for the model. Checked 7 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.

Substantive published commitments across most limbs, short of the one this axis exists for. The Terms of Use define mutual confidentiality with need-to-know access, a 30-day destroy-or-return obligation on request, and liability for the acts of permitted recipients. Clause 12.1 leaves the firm owning the intellectual property in its own data and clause 12.3 licenses that data to Thirdfort only to the extent needed to provide the Services. The data processing agreement makes the firm the controller and Thirdfort the processor, limits processing to the Services and the firm's instructions, and restricts access to personnel who need it. Security measures are specific: AES-256 or stronger at rest, TLS 1.2 or better in transit, two-factor authentication for platform users, least privilege and device encryption for staff, no storage on local machines, and a documented architectural separation of data between different customers. Deletion is concrete, with all initiation and report data removed within 30 days of a written request and the fields covered enumerated down to date of birth and home address. What is absent is privilege and work product, which appear nowhere in the estate. The omission costs a buyer less here than on a matter-facing product, because what Thirdfort holds is client identity and source-of-funds material rather than privileged case files, but the limb is required for the top band and it is not met. Checked 7 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.

Responsibility is allocated in the agreement but no professional conduct framework is engaged. Clause 8 does the allocation squarely: the Reports help a firm understand risk and meet its compliance obligations, they must not be the sole basis of a decision, the firm is solely responsible for the conclusions it draws, and Thirdfort gives no opinion and makes no recommendation. The consumer wording in Appendix 1, which the firm is required to send to its client before lite screening and identity document verification, frames the check as part of the professional's own due diligence rather than as advice from Thirdfort. Both are more than most records carry. What is not addressed is professional conduct as such: nothing engages unauthorised practice, nothing names a conduct rule or regulator obligation that the firm's use of the product touches, and the estate contains no professional responsibility statement. Several limbs of this axis do not bite on a due diligence platform that never advises a client or produces legal work product, and they are not counted against the vendor; the grade reflects that a real allocation exists and a conduct framework does not. Checked 7 September 2026.

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.

No governance disclosure was located anywhere in a legal estate that is otherwise unusually complete. There is no AI policy, no responsible AI or ethics statement, no governance framework, no ISO 42001 or NIST AI RMF alignment, no named internal owner for AI decisions, no model evaluation or testing description, and no AI-specific provision in the Terms of Use, the data processing agreement or the security measures page. The gap is more consequential here than the grade alone conveys, and the reason should be on the record rather than left to inference: the security measures page states that Thirdfort gathers and processes personal data including biometric information from clients, and the product applies automated document and identity checks to individuals whose onboarding depends on the result. Demographic differential performance is a well-documented property of biometric and document-image systems, and nothing published addresses fairness, differential error rates, testing across populations, or what recourse an individual has if a check wrongly flags them. The ISO/IEC 27001:2022 certification governs information security and is not read as covering this. Surfaces read on 7 September 2026: both AI-bearing product pages, the security measures page, the Terms of Use, the data processing agreement, the third-party products and terms, the terms index and the pricing page.

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.

Stewardship is documented at contract level and is genuinely tight, though none of it is AI-specific. Processing is purpose-limited twice over: clause 12.3 of the Terms licenses client data only to the extent needed to provide the Services, and clause 2.4(a) of the data processing agreement limits processing to providing the Services on the firm's instructions. No training or model improvement right is reserved anywhere in the estate. The perpetual feedback licence in clause 12.4 is drafted with an express carve-out stating it will not cover any personal data, which is the kind of detail that usually goes missing. Deletion is concrete and time-bound at 30 days with the fields enumerated. Security measures are specific and independently framed, including annual penetration testing commissioned by the vendor rather than by customers, routine vulnerability scanning, security log monitoring, encryption at rest and in transit, and architectural separation between customers. Breach notification runs without undue delay under the processing agreement, and FCA licensing obliges Thirdfort to file quarterly reports on its operational and security risks, which is external supervision of the security posture rather than self-assertion. What holds this at B is that nothing addresses the AI specifically: no statement covers how document images and biometric material are handled by the model, how long the model's inputs and outputs persist, or whether anything is retained from an inspection once the report is produced. Checked 7 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.

Quantified recourse exists, which is uncommon, and the AI-relevant exposure is routed away from it, which matters. On the credit side the Terms of Use state figures rather than formulas: liability is capped at the higher of 25,000 pounds or the fees paid in the preceding twelve months, with breaches of data protection obligations carved out and capped separately at 2.5 million pounds in aggregate. Clause 6.1(b) warrants that Reports will be materially accurate and complete, mutual intellectual property indemnities run both ways, uptime is committed at 99.5 per cent monthly, material breach carries a 30-day cure, and clause 16.2(b) lets a firm terminate immediately if an update materially reduces the service and no substitute follows. Clause 18 gives an annual audit right with an undertaking to provide executive summaries of audit reports and copies of current third-party certifications. Against that sit three provisions a buyer should weigh together. Clause 9.3(g) excludes losses caused by Third Party Products, which is precisely where the supplier-provided elements of the checks sit. Clause 9.4 waives all the firm's potential claims arising from the Platform, Services or Reports in connection with the services the firm provides to its own client, which is the scenario a firm relying on a regulated due diligence check most needs covered. And uptime is measured from the moment the customer reports a fault in writing rather than from onset, so the commitment turns partly on the customer's own vigilance. Checked 7 September 2026.

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.

An integration surface exists and is contractually governed, but no legal practice system was located first-party. Thirdfort publishes a separate API Agreement in its terms index, applying to clients, partners and potential partners who access the API to build a direct integration, and clause 21 of the Terms of Use incorporates it. Distribution through Partner Platforms is a first-class part of the model rather than an afterthought: clause 2.2(b) contemplates a firm using the Platform Services entirely through a partner's own platform, clause 19 governs the information exchanged, and a partners list is maintained at a published address. That is real integration depth in architecture. What could not be established is direction: no case management system, practice management system, document management system or legal accounting package is named in any surface read, so a buyer cannot tell from the vendor's own material which systems the product actually plugs into. The partners list itself was not opened in this pass and is named here as the artifact that would settle it; it is the row in this record most likely to move on a further pass, and it is amendable on newly located evidence. Checked 7 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 is addressed and region is not, which clears the floor on the tenancy limb alone. The security measures page states that Thirdfort hosts its technical infrastructure and databases on Google Cloud Platform, that data sits in GCP-managed database services across three data centres at different physical sites, that storage on local machines is not permitted, and that the software architecture ensures separation of data and of information security between different customers and application components. That is a documented multi-customer separation model rather than a bare assertion. Residency is the weaker half. The three data centres are not located for the reader, no region menu or residency choice is offered, and the vendor states plainly that it uses service providers located outside the United Kingdom and European Union, relying on contractual transfer mechanisms rather than on keeping data in region. Those mechanisms are properly specified: the data processing agreement incorporates module 2 of the EU Standard Contractual Clauses and the UK International Data Transfer Addendum, with Thirdfort as importer and the firm as exporter. The completed transfer schedules that would show the actual destinations are published as images and could not be read, which is recorded as a retrieval limit rather than an absence. No self-hosted or private deployment option exists, which is expected for a consumer-app-based verification service. Checked 7 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.

Multiple current, independently granted certifications, published without a portal. Thirdfort states it holds ISO/IEC 27001:2022, the current revision of the standard rather than a superseded one, and separately holds certification as an Identity Service Provider under the Digital Identity and Attributes Trust Framework operated by the UK government's Department for Science, Innovation and Technology. It is certified under the UK Digital Verification Services trust framework and appears on the GOV.UK register of digital identity services, which is a public register a buyer can check independently of anything the vendor says. Regulatory supervision adds a further layer that is not a certification but functions like one: FCA licensing for account information services means, in the vendor's own account, that the regulator has reviewed its security policies and that Thirdfort must file quarterly reports on operational and security risks. Penetration testing is annual and vendor-commissioned, with remediation routed into engineering priority, alongside routine vulnerability scanning and security log monitoring. What holds this below the top band is artifact access. No certificate document, certificate number or validity period is published, no auditor or certification body is named, there is no SOC 2 report, and there is no trust centre or document portal. Certifications are obtainable, but through clause 18.2 on request during an audit rather than from the website, and clause 18.3 expressly excludes access to non-public external reports. Checked 7 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.

The supply chain is partly disclosed, and the part that is disclosed is done properly. Six suppliers are named in a published, versioned instrument with their full flow-down terms reproduced: Onfido, Experian, IVXS UK trading as ComplyAdvantage, iProov, Dun and Bradstreet, and Kyckr Ireland. A separate third-party service provider page, dated 24 October 2025, distinguishes data providers from technical service providers, explains the two categories of data shared, and offers a subscription to sub-processor notices. Change is governed contractually: clause 16.2 of the Terms gives 30 days' notice of any material change to the data provider list with a right to terminate, and clause 3.3 of the processing agreement requires written notice of new sub-processors within 30 days with a right to object. Experian's own flow-down terms disclose that its services involve models and techniques based on statistical analysis, probability and predictive behaviour, which is supplier-level model disclosure a buyer can read. What is missing is the mapping and the models. No model is named anywhere, no version or family is given, and the vendor never states which of the six suppliers, if any, provides the artificial intelligence behind document verification. Naming Google Cloud Platform tells a reader where the service runs, not whose model inspects a passport, and it is credited on deployment rather than counted twice here. Two artifacts that would close the gap could not be read and are recorded as retrieval limits: the feature-to-provider breakdown on the flow-down page is published as an image, and the provider tables on the service provider page render client-side and returned no content. Checked 7 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.

Commercial mechanics are published in the contract while prices are not published anywhere. The pricing page exists and is structured by buyer type, inviting a reader to select an industry to see available plans, with a custom quote offered for industries not listed. The plan detail sits behind that selector and rendered no content, which is recorded as unrendered rather than absent because the page's own wording states that plans are there to be seen. What is established first-party comes from the Terms of Use, and it is more than a sales invitation: fees are agreed separately and are exclusive of VAT, any increase carries 30 days' notice with an opportunity to stop using the service, disputed invoices must be raised within 30 days, overdue amounts carry interest at 4 per cent above the Barclays base rate, suspension follows 7 days' notice, minimum purchase commitments exist and survive early termination, and a discounted trial period may be offered at the vendor's discretion. Those are real commercial terms a buyer can rely on. What is absent is any figure, band or unit of charge: the product is bought as checks and plans, and no price per check, per seat or per plan appears on any surface read. The grade sits above the floor because published pricing information exists at the level of charging mechanics, and below the middle band because no rate is discoverable without a sales conversation. Checked 7 September 2026.

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.

Coverage is deep in one practice area and deliberately narrow beyond it. Legal is one of four named sectors with a page of its own, alongside conveyancing, estate agents and accountants, and the insights library carries a dedicated Lawyers industry category with material aimed squarely at solicitors, including guidance on file notes that survive an SRA review and on enhanced due diligence after the 2026 Money Laundering Regulations reforms. Practice depth is strongest in property: the enhanced NFC identity check is built to HM Land Registry's Safe Harbour standard under Practice Guide 81, and the platform supports Authorised Corporate Services Providers meeting the Companies House identity verification standard for directors and persons of significant control. Geographic reach in the checks themselves is broad, covering documents from 195 jurisdictions and electronic address verification across 17. What holds this at B is that the practice surface is a single workflow rather than a range: client onboarding and anti-money-laundering diligence, with no other legal practice area addressed and no matter-type coverage statement. The regulatory frame is also single-jurisdiction, resting on FCA authorisation, HM Land Registry, Companies House, the SRA and English governing law, so a firm outside the United Kingdom sees a product built around a compliance regime that is not its own. The legal sector page redirected to an insights article when fetched and was not read directly; the sector's existence and its content are established from the site navigation and the insights category. Checked 7 September 2026.