



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

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF).  Note that other groups may also distribute
   working documents as Internet-Drafts.  The list of current Internet-
   Drafts is at https://datatracker.ietf.org/drafts/current/.

   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."




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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/
   license-info) in effect on the date of publication of this document.
   Please review these documents carefully, as they describe your rights
   and restrictions with respect to this document.

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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