Diligent Institute, the corporate governance research arm and think tank of Diligent, and Wilson Sonsini, a leading global law firm, today released findings from the Q4 General Counsel (GC) Risk Index revealing how regulatory uncertainty, AI adoption and cybersecurity threats are creating an increasingly complex risk environment for legal leaders.

“Nearly six in 10 legal leaders say AI adoption is outpacing governance. That gap is a risk in itself: as AI spreads across an organization, it becomes harder to maintain clear visibility into how it is used, what data it touches and who is accountable,” said Dottie Schindlinger, Executive Director of Diligent Institute. “Boards do not need every director to be an AI expert, but they do need enough fluency to challenge assumptions and ensure oversight keeps pace with adoption.”

AI use is faster than oversight

  • Nearly 60% of legal leaders say AI governance is struggling to keep pace with adoption, highlighting the challenge of establishing effective oversight without slowing innovation.

  • 41% of respondents lack an established basic AI governance framework, with 14% reporting no formal approach and 27% still developing policies and guidelines. While organizations are making progress, continuous monitoring and improvement remain areas for development.

  • Legal professionals rate their boards’ readiness to oversee AI risk at 2.9 out of 5 on average. The plurality of respondents rate board readiness at the midpoint, suggesting willingness and engagement around AI oversight rather than full preparedness.

Risk remains elevated, with regulation, AI and cyber leading

  • 59% of respondents rate their organizational risk as high; regulatory change tops the risk list at 55%, followed by AI-related risk at 49% and cyber threats at 47%.

  • Since Q2, geopolitical conflict fell from 52% to 26%, while regulatory change rose from 48% to 55%, AI-related risk from 39% to 49%, and cyber threats from 39% to 47%.

  • Workforce, culture and talent risks (34%), geopolitical conflicts (26%) and supply-chain disruptions (24%) round out respondents’ next most-cited concerns.

AI governance is distributed, but accountability can be unclear

  • Legal teams are actively involved in AI due diligence: 67% review vendors and assess privacy, data, confidentiality and intellectual property issues; while also evaluating legal and regulatory risk and developing guardrails.

  • Strategic visibility is less consistent: Only 23% say their legal teams regularly brief the board or senior leadership on AI-related risks, while governance is most often housed with IT, security, or a data/digital function.

  • The results suggest an opportunity to involve legal teams earlier in decision-making to help shape risk appetite, influence tool and data decisions, establish controls and strengthen board reporting around AI—not just review vendor contracts.

“As risks like AI and cybersecurity evolve at breakneck speed, boards need a clear understanding of their potential legal, regulatory and disclosure implications, and how management is responding,” said Sachin Kohli, Partner at Wilson Sonsini. “Legal leaders have a critical role to play in connecting these risks across the enterprise, working alongside Risk, Compliance and Security to translate complex challenges into actionable insights. This means giving boards the visibility to anticipate emerging risks and prioritize oversight.”

Download the Q4 2026 GC Risk Index to explore the report’s full findings.

Methodology

The Q4 2026 GC Risk Index was conducted as an online survey of approximately 200 General Counsel, Chief Legal Officers, and other legal leaders. The survey fielded from late July to late September 2026. About 70% of respondents represent organizations based in North America. Fifty-one percent represent private companies and 28% represent publicly held companies. The full demographics are presented in a standalone section at the end of the report.

About Diligent Institute

Diligent Institute informs, educates, and connects leaders to champion governance excellence. We meet this mission through original, cutting-edge research on critical corporate governance issues, certificate programs for corporate leaders, peer networks that convene directors and executives to share best practices, and recognition programs that celebrate governance excellence. Diligent Institute was founded in 2018 as Diligent’s global corporate governance research arm and think tank. Learn more at diligentinstitute.com.

About Wilson Sonsini

For more than 65 years, Wilson Sonsini’s services and legal disciplines have focused on serving the principal challenges faced by the management and boards of directors of business enterprises. The firm is nationally recognized as a leading provider to growing and established clients seeking legal counsel to complete sophisticated corporate and technology transactions; manage governance and enterprise-scale matters; assist with intellectual property development, protection, and IP-driven transactions; represent them in contested disputes; and/or advise them on antitrust or other regulatory matters. With deep roots in Silicon Valley, Wilson Sonsini has more than 1,000 attorneys and 17 offices in 16 technology, business, and regulatory markets across the United States, Asia, and Europe. For more information, please visit www.wsgr.com.

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