OMP Domain Profile: Legal AI Supervision Under ABA Model Rule 5.3 and California Senate Bill 574
draft-veridom-omp-legal-00
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| Authors | Tolulope Adebayo , Oluropo Apalowo , Festus Makanjuola | ||
| Last updated | 2026-04-03 | ||
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draft-veridom-omp-legal-00
Internet Engineering Task Force T. Adebayo
Internet-Draft O. Apalowo
Intended status: Informational F. Makanjuola
Expires: 7 October 2026 Veridom Ltd
5 April 2026
OMP Domain Profile: Legal AI Supervision Under ABA Model Rule 5.3 and
California Senate Bill 574
draft-veridom-omp-legal-00
Abstract
This document defines a domain profile of the Operating Model
Protocol (OMP) for legal AI deployments subject to attorney
supervision obligations under ABA Model Rule 5.3 Responsibilities
Regarding Nonlawyer Assistance and California Senate Bill 574 (SB
574, effective January 1, 2026). These instruments impose principal
accountability requirements on attorneys who use AI tools to assist
with legal work product -- requiring attorneys to verify AI-generated
material, ensure compliance with professional duties, and maintain
evidence of supervision.
This profile specifies how OMP's deterministic routing invariant,
Watchtower enforcement framework, and three-layer cryptographic
integrity architecture satisfy the attorney supervision obligations
imposed by Rule 5.3 and SB 574, and defines the domain-specific
Watchtower configurations, Named Accountable Officer assignments, and
Audit Trace schema extensions applicable to legal AI deployments.
The profile is designated the CiteGuard profile.
The OMP core specification is defined in a separate Internet-Draft.
Status of This Memo
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provisions of BCP 78 and BCP 79.
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This Internet-Draft will expire on 7 October 2026.
Copyright Notice
Copyright (c) 2026 IETF Trust and the persons identified as the
document authors. All rights reserved.
This document is subject to BCP 78 and the IETF Trust's Legal
Provisions Relating to IETF Documents (https://trustee.ietf.org/
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Please review these documents carefully, as they describe your rights
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Table of Contents
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . 3
2. Terminology . . . . . . . . . . . . . . . . . . . . . . . . . 4
3. Legal Framework Analysis . . . . . . . . . . . . . . . . . . 4
3.1. ABA Model Rule 5.3 . . . . . . . . . . . . . . . . . . . 5
3.2. California SB 574 . . . . . . . . . . . . . . . . . . . . 5
3.3. Convergent Requirements . . . . . . . . . . . . . . . . . 6
4. OMP CiteGuard Profile . . . . . . . . . . . . . . . . . . . . 6
4.1. Routing States Under This Profile . . . . . . . . . . . . 6
4.2. Named Accountable Officer: The Supervising Attorney . . . 7
4.3. Watchtower Definitions . . . . . . . . . . . . . . . . . 7
4.3.1. WT-LEGAL-01: Supervising Attorney Gate . . . . . . . 7
4.3.2. WT-LEGAL-02: Confidentiality Boundary Gate . . . . . 7
4.3.3. WT-LEGAL-03: Citation Verification Gate . . . . . . . 8
4.3.4. WT-LEGAL-04: Hallucination Detection Gate . . . . . . 8
4.3.5. WT-LEGAL-05: Bias Detection Gate . . . . . . . . . . 8
4.3.6. WT-LEGAL-06: Non-Delegation Gate . . . . . . . . . . 8
4.4. Audit Trace Schema Extensions . . . . . . . . . . . . . . 9
5. The CiteGuard Invariant . . . . . . . . . . . . . . . . . . . 10
6. Proof-Point as Supervision Evidence . . . . . . . . . . . . . 10
7. Interaction with Legal Privilege . . . . . . . . . . . . . . 11
8. Security Considerations . . . . . . . . . . . . . . . . . . . 11
9. IANA Considerations . . . . . . . . . . . . . . . . . . . . . 11
10. References . . . . . . . . . . . . . . . . . . . . . . . . . 11
10.1. Normative References . . . . . . . . . . . . . . . . . . 11
10.2. Informative References . . . . . . . . . . . . . . . . . 12
Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . 12
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1. Introduction
The deployment of AI in legal practice has accelerated substantially
since 2024, driven by improvements in large language model
capabilities for legal research, contract analysis, brief drafting,
and citation generation. Law firms, corporate legal departments, and
legal technology companies now routinely use AI systems to assist
with work product that bears attorney signatures and carries
professional and legal accountability.
Two instruments have crystallised the attorney supervision
obligations that apply to AI-assisted legal work:
* ABA Model Rule 5.3, [ABA-RULE-5-3] as clarified by ABA Formal
Opinion 512 [ABA-OP-512] (July 2023), establishes that attorneys
must make reasonable efforts to ensure that the conduct of
nonlawyer assistance -- including AI tools -- is compatible with
the attorney's professional obligations. Attorneys must
understand the capabilities and limitations of AI tools, verify
AI-generated material for accuracy, and maintain a supervisory
relationship over AI outputs that become part of legal work
product.
* California Senate Bill 574 (effective January 1, 2026) extends
these obligations with specific requirements: attorneys must
ensure that confidential client information is not disclosed to
public AI systems, must verify and correct AI-generated material,
must remove AI-generated content that may contain bias, and must
personally verify citations and case references included in
submitted filings. SB 574 also prohibits arbitrators from
delegating decision-making authority to AI systems.
These instruments impose a structural evidence requirement: an
attorney who relies on AI assistance for legal work product must be
able to demonstrate, if challenged, that they supervised the AI tool,
reviewed its output, exercised independent professional judgment, and
corrected errors before the work product was submitted or delivered.
The Operating Model Protocol (OMP) [I-D.veridom-omp] is a
deterministic decision-enforcement protocol that generates a tamper-
evident Audit Trace at the point of every AI-assisted decision.
Applied to legal AI deployments, OMP provides the evidence
infrastructure that makes attorney supervision provable rather than
merely asserted.
This document defines the CiteGuard profile: the domain-specific
instantiation of OMP for legal AI supervision under Rule 5.3 and SB
574. The name reflects the profile's primary enforcement focus:
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ensuring that every citation, reference, and claim in AI-assisted
legal work product is verifiably reviewed by a named supervising
attorney before delivery or filing.
The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT",
"SHOULD", "SHOULD NOT", "RECOMMENDED", "MAY", and "OPTIONAL" in this
document are to be interpreted as described in [RFC2119] [RFC8174].
2. Terminology
This document uses the terminology defined in [I-D.veridom-omp]. In
addition:
Supervising Attorney The licensed attorney who bears professional
responsibility for an AI-assisted legal interaction under Rule 5.3
or SB 574. In OMP terms, the Supervising Attorney is the Named
Accountable Officer for ASSISTED and ESCALATED interactions.
Legal Work Product Any document, analysis, draft, filing, research
output, or communication produced with AI assistance that is
delivered to a client, submitted to a court or arbitral tribunal,
or used in a legal proceeding.
AI-Assisted Legal Interaction Any interaction in which an AI system
contributes to the generation, verification, analysis, or citation
of legal content that becomes or may become part of Legal Work
Product.
Citation Verification The act of a Supervising Attorney confirming
that a case citation, statutory reference, regulatory citation, or
other legal authority cited in AI-generated content accurately
represents the cited source and is applicable to the stated
proposition.
CiteGuard Invariant The two-property invariant defined in Section 5:
every AI-assisted legal interaction is routed to ASSISTED or
ESCALATED (never AUTONOMOUS for Legal Work Product), and every
routing produces a sealed, independently verifiable CiteGuard
Audit Trace.
Privilege Review Flag A field in the CiteGuard Audit Trace
indicating whether the interaction involved content subject to
attorney-client privilege or work product doctrine.
3. Legal Framework Analysis
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3.1. ABA Model Rule 5.3
ABA Model Rule 5.3 requires that attorneys with supervisory authority
over nonlawyer assistants make reasonable efforts to ensure that the
assistants' conduct is compatible with the professional obligations
of the attorney. ABA Formal Opinion 512 (July 2023) applies this
obligation to AI tools used in legal practice.
The supervision obligation under Rule 5.3 has three components
relevant to AI deployments:
* *Competence obligation:* An attorney who uses an AI tool must
understand the tool's capabilities and limitations to a degree
sufficient to supervise its outputs. This includes understanding
the tool's propensity to generate hallucinated citations, its
training data cutoff, and its limitations with jurisdiction-
specific law.
* *Verification obligation:* An attorney must review AI-generated
work product for accuracy before delivery or use. For citations,
this means personally verifying that the cited authority exists
and supports the stated proposition.
* *Accountability obligation:* The attorney bears professional
responsibility for AI-generated work product delivered under the
attorney's name. The attorney cannot delegate this accountability
to the AI tool.
3.2. California SB 574
California Senate Bill 574, [CA-SB574] effective January 1, 2026,
imposes attorney supervision requirements specific to California
practice:
* *Confidentiality:* Attorneys must ensure that confidential client
information is not entered into public AI systems without client
consent.
* *Verification and correction:* Attorneys must personally verify
AI-generated material and correct any errors, inaccuracies, or
misleading content.
* *Bias removal:* Attorneys must review AI-generated content for
potential bias and remove any biased analysis.
* *Citation verification:* Attorneys must personally verify all
citations, case references, and statutory references included in
filings or documents submitted to courts or arbitral tribunals.
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* *Non-delegation:* Arbitrators and attorneys acting as decision-
makers may not delegate the decision itself to an AI system.
3.3. Convergent Requirements
Rule 5.3 and SB 574, taken together, define a structure that maps
directly onto OMP's three routing states:
* AI-generated content reviewed and approved by the Supervising
Attorney without modification corresponds to the ASSISTED routing
state.
* AI-generated content requiring correction, subsequently corrected
and approved, corresponds to the ESCALATED routing state with
resolution.
* Any AI-generated interaction where supervision evidence cannot be
produced corresponds to the structural gap that OMP closes.
Under this profile, there are no AUTONOMOUS routing outcomes for AI-
Assisted Legal Work Product interactions. Every such interaction
MUST be routed to ASSISTED or ESCALATED.
4. OMP CiteGuard Profile
4.1. Routing States Under This Profile
AUTONOMOUS NOT PERMITTED for AI-Assisted Legal Interactions under
this profile. Implementations MUST configure WT-LEGAL-01 as a
universal FORCE_ASSISTED trigger for all interactions classified
as Legal Work Product. AUTONOMOUS routing is reserved for non-
Legal-Work-Product interactions only.
ASSISTED The standard routing state for AI-Assisted Legal
Interactions. The Supervising Attorney's identity, review
timestamp, approval decision, and any corrections are recorded in
the CiteGuard Audit Trace.
ESCALATED Triggered by Watchtower detection of a confidentiality
breach, citation verification failure, hallucinated authority,
detected bias, or non-delegation violation. The AI system's
output MUST NOT be delivered or filed until the Supervising
Attorney has reviewed, corrected, and approved.
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4.2. Named Accountable Officer: The Supervising Attorney
Under the CiteGuard profile, the Named Accountable Officer for every
ASSISTED and ESCALATED interaction is the Supervising Attorney. The
Supervising Attorney MUST be a licensed attorney in the jurisdiction
where the Legal Work Product will be used.
The following fields are REQUIRED in the Supervising Attorney record:
* supervising_attorney_id: unique deployment identifier;
* supervising_attorney_bar_jurisdiction: ISO 3166-2 codes for
licensed jurisdictions;
* review_timestamp: ISO 8601 UTC of the review action;
* review_decision: one of APPROVED, APPROVED_WITH_CORRECTIONS,
RETURNED_FOR_REWORK;
* corrections_summary: REQUIRED if review_decision is not APPROVED.
4.3. Watchtower Definitions
4.3.1. WT-LEGAL-01: Supervising Attorney Gate
*Trigger:* Any AI-Assisted Legal Interaction.
*Action:* FORCE_ASSISTED.
*Rationale:* Rule 5.3 and SB 574 impose non-waivable attorney
supervision obligations. This Watchtower makes it architecturally
impossible for an AI-Assisted Legal Interaction to proceed to
delivery or filing without generating a supervision evidence record.
It cannot be disabled for Legal Work Product interactions.
4.3.2. WT-LEGAL-02: Confidentiality Boundary Gate
*Trigger:* Interaction payload contains client confidential
information destined for an AI system outside an approved
confidentiality boundary.
*Action:* HARD_BLOCK.
*Rationale:* SB 574 requires attorneys to ensure that confidential
client information is not entered into public AI systems. Rule 1.6
applies independently. HARD_BLOCK ensures violations cannot occur
without a blocking record.
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4.3.3. WT-LEGAL-03: Citation Verification Gate
*Trigger:* Output contains citations to legal authorities not yet
verified against an accessible source within the current interaction.
*Action:* FORCE_ESCALATED.
*Rationale:* SB 574 requires attorneys to personally verify citations
in filings. This Watchtower enforces that obligation structurally:
AI-generated content with unverified citations cannot be approved
without an attorney citation verification record.
4.3.4. WT-LEGAL-04: Hallucination Detection Gate
*Trigger:* Output contains a citation, case name, or legal authority
that cannot be located in accessible legal databases, or where the
cited passage does not appear at the cited location.
*Action:* HARD_BLOCK for submissions; FORCE_ESCALATED for drafts.
*Rationale:* AI hallucination of legal citations is a documented
pattern resulting in court sanctions and professional discipline.
This Watchtower provides pre-submission enforcement. The CiteGuard
Audit Trace records the unverifiable citation, the database query
result, and the Supervising Attorney's disposition.
4.3.5. WT-LEGAL-05: Bias Detection Gate
*Trigger:* Operator's bias detection module flags potential biased
analysis, discriminatory framing, or stereotyped characterisation.
*Action:* FORCE_ESCALATED.
*Rationale:* SB 574 requires attorneys to remove AI-generated content
that reflects bias. The Watchtower ensures bias flags generate a
supervision record with Supervising Attorney disposition.
4.3.6. WT-LEGAL-06: Non-Delegation Gate
*Trigger:* AI output constitutes or is intended to constitute a final
decision in a matter where an attorney or arbitrator is the
designated decision-maker (arbitral award, legal opinion delivered as
final determination).
*Action:* HARD_BLOCK.
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*Rationale:* SB 574 prohibits arbitrators from delegating decision-
making authority to AI systems. Rule 5.3 requires independent
professional judgment. The AI system's analysis may inform the
decision as ASSISTED input, but the decision record MUST reflect the
human decision-maker's independent judgment.
4.4. Audit Trace Schema Extensions
The following fields are REQUIRED in the Audit Trace schema under the
CiteGuard profile, in addition to the core fields defined in
[I-D.veridom-omp] Section 7:
supervising_attorney_id string, REQUIRED for ASSISTED and ESCALATED
outcomes.
supervising_attorney_bar_jurisdiction string, REQUIRED. Comma-
separated ISO 3166-2 codes. Example: "US-CA,US-NY".
review_timestamp string, ISO 8601 UTC, REQUIRED for ASSISTED and
ESCALATED outcomes.
review_decision string, REQUIRED. One of: APPROVED,
APPROVED_WITH_CORRECTIONS, RETURNED_FOR_REWORK.
corrections_summary string, OPTIONAL if APPROVED; REQUIRED
otherwise.
citations array of objects, REQUIRED if the interaction generated
legal citations. Each object MUST contain: citation_text,
source_verified (boolean), verification_method,
verification_timestamp (ISO 8601 UTC), verified_by (one of:
"AI_SYSTEM", "SUPERVISING_ATTORNEY").
work_product_type string, REQUIRED. RECOMMENDED values:
"court_filing", "client_advice", "contract_draft",
"legal_research", "arbitral_submission", "internal_memo".
privilege_review_flag boolean, REQUIRED. True if the interaction
involved potentially privileged content.
confidentiality_boundary_verified boolean, REQUIRED. True if WT-
LEGAL-02 evaluated the target AI system.
profile_version string, REQUIRED. MUST be "VERIDOM-CITEGUARD-v1.0"
for this profile version.
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5. The CiteGuard Invariant
Implementations of this profile MUST satisfy the following two-
property invariant:
Property 1 (Supervision completeness) Every AI-Assisted Legal
Interaction that contributes to Legal Work Product MUST generate a
sealed CiteGuard Audit Trace containing a Supervising Attorney
review record before the work product is delivered or filed.
Property 2 (Immutable trail) The CiteGuard Audit Trace MUST be
sealed with the three-layer integrity architecture defined in
[I-D.veridom-omp] Section 7 (SHA-256 chain, RFC 3161
TimeStampToken, institution signature). Any modification to any
historical Audit Trace record MUST be detectable by any third
party without access to the operator's or implementer's
infrastructure.
These two properties mean that for any AI-Assisted Legal Interaction
processed under this profile, an attorney facing a Rule 5.3 or SB 574
compliance inquiry can produce: (a) a sealed, tamper-evident record
of the specific AI output; (b) the Supervising Attorney's identity,
review timestamp, and decision; (c) citation verification records for
every citation in the output; (d) Watchtower evaluation results; and
(e) an independently verifiable integrity proof that the records have
not been modified since sealing.
6. Proof-Point as Supervision Evidence
The OMP Proof-Point artefact generation mechanism (defined in
[I-D.veridom-omp] Section 7.5) produces a self-contained supervision
evidence package for any defined time window. Under this profile,
the Proof-Point artefact for a legal deployment MUST include, for
each AI-Assisted Legal Interaction: the full CiteGuard Audit Trace,
the Supervising Attorney review record, citation verification
records, Watchtower evaluation log, chain integrity proof (SHA-256
Merkle root), and RFC 3161 TimeStampToken verification output from
the OMP Reference Validator [OMP-OPEN-CORE].
This artefact is designed to be self-contained: a disciplinary
authority, court, or malpractice insurer with no access to the
operator's systems can verify its integrity and completeness using
only the OMP Reference Validator and the public key material of the
Timestamp Authority.
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7. Interaction with Legal Privilege
CiteGuard Audit Trace records may contain information subject to
attorney-client privilege or work product doctrine. Operators MUST
apply the privilege_review_flag field. The existence of the Audit
Trace does not waive privilege; the records were created as part of
the supervisory process, not for disclosure to adverse parties.
The chain integrity proof (Merkle root and TimeStampToken) can be
disclosed to demonstrate that a complete Audit Trace exists and has
not been tampered with, without disclosing the content of individual
records. This allows attorneys to assert the integrity of their
supervision records without waiving privilege over their content.
8. Security Considerations
The security considerations of [I-D.veridom-omp] apply in full to
this profile.
Supervising attorney identity: Operators MUST ensure that
supervising_attorney_id values cannot be spoofed or assigned to non-
attorneys within the deployment system.
Review timestamp integrity: The review_timestamp field MUST be set by
the OMP pipeline at the time of the review action. Operators MUST
ensure the pipeline clock is monotonic and cannot be manipulated to
backdate supervision records.
Citation database availability: WT-LEGAL-03 and WT-LEGAL-04 depend on
legal database access. Operators MUST treat database unavailability
as a C_d reduction event, routing interactions to ESCALATED where
citation verification cannot be performed.
9. IANA Considerations
This document has no IANA actions.
10. References
10.1. Normative References
[I-D.veridom-omp]
Adebayo, T., Apalowo, O., and F. Makanjuola, "Operating
Model Protocol (OMP): A Deterministic Decision-Enforcement
Protocol with Externalized Proof-of-Integrity", Work in
Progress, Internet-Draft, draft-veridom-omp-00, March
2026, <https://datatracker.ietf.org/doc/html/draft-
veridom-omp-00>.
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[RFC2119] Bradner, S., "Key words for use in RFCs to Indicate
Requirement Levels", BCP 14, RFC 2119,
DOI 10.17487/RFC2119, March 1997,
<https://www.rfc-editor.org/info/rfc2119>.
[RFC8174] Leiba, B., "Ambiguity of Uppercase vs Lowercase in RFC
2119 Key Words", BCP 14, RFC 8174, DOI 10.17487/RFC8174,
May 2017, <https://www.rfc-editor.org/info/rfc8174>.
10.2. Informative References
[ABA-OP-512]
ABA Standing Committee on Ethics and Professional
Responsibility, "Formal Opinion 512: Generative Artificial
Intelligence Tools", July 2023.
[ABA-RULE-5-3]
American Bar Association, "ABA Model Rules of Professional
Conduct, Rule 5.3: Responsibilities Regarding Nonlawyer
Assistance", 2023.
[CA-SB574] California Legislature, "Senate Bill 574: Attorneys:
Artificial Intelligence", January 2026.
[I-D.veridom-omp-euaia]
Adebayo, T., Apalowo, O., and F. Makanjuola, "OMP Domain
Profile: EU AI Act Article 12 Logging and Traceability
Requirements for High-Risk AI System Operators", Work in
Progress, Internet-Draft, draft-veridom-omp-euaia-00,
April 2026, <https://datatracker.ietf.org/doc/html/draft-
veridom-omp-euaia-00>.
[OMP-OPEN-CORE]
Veridom Ltd, "OMP Open Core: Reference Validator and
Schema Library", Apache 2.0,
https://github.com/veridomltd/omp-open-core, 2026.
[ZENODO-OMP]
Adebayo, T., Apalowo, O., and F. Makanjuola, "OMP --
Operating Model Protocol: A Deterministic Routing
Invariant for Tamper-Evident AI Decision Accountability in
Regulated Industries", Zenodo DOI 10.5281/zenodo.19140948,
March 2026.
Authors' Addresses
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Tolulope Adebayo
Veridom Ltd
London
United Kingdom
Email: tolulope@veridom.io
Oluropo Apalowo
Veridom Ltd
Awka
Nigeria
Email: ropo@veridom.io
Festus Makanjuola
Veridom Ltd
Toronto
Canada
Email: festus@veridom.io
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