Compliance Reference · Florida Practice

AI Compliance Crosswalk for Florida Lawyers

How Florida Bar Ethics Opinion 24-1, ABA Formal Opinion 512, the Florida Rules of Professional Conduct, and the 11th and 17th Circuit administrative orders map to operational requirements for solo and small firm practice.

This is a practitioner reference. It summarizes how the controlling authorities address each requirement. It does not reproduce them.

The Landscape

What changed, and what most firms still lack.

Florida lawyers now operate under three coordinated layers of expectation when using generative AI. Florida Bar Ethics Opinion 24-1 sets the substantive ethics framework. ABA Formal Opinion 512 reinforces it nationally. The 11th and 17th Judicial Circuits have now added administrative orders requiring verification of citations, factual claims, and conclusions on court submissions, plus protection against confidentiality breaches and inappropriate language.

What’s missing in most solo and small firm practices isn’t awareness of the duty. It’s the written protocol. The protocol that says who verifies what, when, and how the verification is documented. Without that record, a lawyer who’s asked six months from now how a particular filing was verified has nothing to point to.

This crosswalk maps the requirements across the controlling authorities so a small firm can see, in one place, what compliance looks like operationally. The administrative orders specifically referenced are 11th Judicial Circuit Administrative Order No. 26-15 (issued May 19, 2026, rescinding Administrative Order No. 26-04) and 17th Judicial Circuit Administrative Order 2026-03-Gen (Amendment 2) (issued May 19, 2026). The full protocol for building and documenting verification workflows is in Responsible AI for the Small Law Firm.

The Crosswalk

How the requirements map.

Eight operational requirements and a disclosure safe harbor, each mapped across the four controlling authorities. The mapping is a summary, not a reproduction of the source text.

Reading the columns

Florida Bar Opinion 24-1. Florida Bar Ethics Opinion 24-1, the state ethics framework for generative AI.

Opinion 512. ABA Formal Opinion 512, the national ABA guidance.

Florida Rules. The Florida Rules of Professional Conduct.

Circuit Orders. Administrative orders of the 11th and 17th Judicial Circuits on AI use.

Requirement 1

Competence with AI tools

Operational requirementUnderstand what the tool can and cannot do before using it in client work.

Florida Bar Opinion 24-1

Confirms Rule 4-1.1 competence extends to generative AI.

Opinion 512

Requires a reasonable understanding of the tool’s capabilities, limitations, and risks.

Florida Rules

Rule 4-1.1 and related technological competence comments.

Generative-AI comment amendments: In re Amendments to Rules Regulating the Florida Bar - Chapter 4, 393 So. 3d 137 (Fla. 2024) (SC2024-0032).

Circuit Orders

11th Circuit AO 26-15 and 17th Circuit AO 2026-03-Gen (Amendment 2) confirm permitted use with required human oversight, referencing SC2024-0032 amendments to comments on Rules 4-1.1, 4-1.6, 4-5.1, and 4-5.3.

Requirement 2

Confidentiality of client information

Operational requirementDo not input client confidences into AI tools that may use, store, or train on the data without informed consent and appropriate protections.

Florida Bar Opinion 24-1

Addresses Rule 4-1.6 obligations and informed consent considerations.

Opinion 512

Requires assessment of the tool’s data handling.

Florida Rules

Rule 4-1.6.

Circuit Orders

17th Circuit AO 2026-03-Gen (Amendment 2) section 5 (‘Confidentiality and Authenticity’) requires best-efforts authenticity verification and consistency with the obligation to protect confidential information. 11th Circuit AO 26-15 addresses confidentiality by reference to Rule 4-1.6 in the Attorney Responsibility section.

Requirement 3

Verification of citations

Operational requirementEvery authority cited in a submission must be independently verified against the source.

Florida Bar Opinion 24-1

AI-generated citations must be confirmed.

Opinion 512

Lawyer remains responsible for accuracy, including citations.

Florida Rules

Rule 4-3.3.

Circuit Orders

All citations must be verified. Human oversight must include checking citations.

Requirement 4

Verification of factual claims and conclusions

Operational requirementAI-generated factual statements and reasoning must be independently checked, not adopted by default.

Florida Bar Opinion 24-1

Factual claims must be verified and conclusions assessed.

Opinion 512

Requires critical evaluation of AI output before relying on it.

Florida Rules

Rules 4-1.1 and 4-3.3.

Circuit Orders

Both orders require personal review and verification of every citation to the law or the record, and the accuracy of any language drafted by generative AI, including quotations, citations, paraphrased assertions, facts, and legal analysis.

Order text: “human oversight that includes checking citations, verifying factual claims, and analyzing conclusions” (AO 26-15 section 3; AO 2026-03-Gen (Amendment 2) section 1).

Requirement 5

Professional language and tone

Operational requirementAI output going under the lawyer’s name must meet professional standards. The duty extends beyond accuracy to voice.

Florida Bar Opinion 24-1

Treats AI output as the lawyer’s own work product.

Opinion 512

Lawyer is responsible for what is filed regardless of source.

Florida Rules

Applicable rules of decorum and Florida professionalism standards.

Circuit Orders

Both orders require users to guard against inappropriate language in AI-generated content.

17th Circuit AO 2026-03-Gen (Amendment 2) section 1 uses the phrase ‘the use of inappropriate language.’ 11th Circuit AO 26-15 section 3 contains the parallel provision with the phrase ‘the use of appropriate language’ (an awkward construction the 17th Circuit corrected in Amendment 2; the substantive meaning is the same).

Requirement 6

Candor to the tribunal

Operational requirementAI-generated material that turns out to be false must be corrected. AI cannot insulate the lawyer from candor obligations.

Florida Bar Opinion 24-1

Rule 4-3.3 applies regardless of the source of the false statement.

Opinion 512

Lawyer cannot delegate candor to a tool.

Florida Rules

Rule 4-3.3.

Circuit Orders

11th Circuit AO 26-15 includes a Duty of Candor and Responsibility section.

Order text: “All AI-generated content will be deemed the filing party’s submission” (AO 26-15 section 8).

Requirement 7

Supervision and human oversight

Operational requirementTreat AI output the way Rule 4-5.3 requires the lawyer to treat nonlawyer assistant work product. Review, verify, accept responsibility.

Florida Bar Opinion 24-1

Applies Rule 4-5.3 framework by analogy.

Opinion 512

Adopts a supervision-style framework for AI output.

Florida Rules

Rule 4-5.3, applied by analogy.

Circuit Orders

All AI-generated information must have appropriate human oversight.

Requirement 8

Client communication

Operational requirementWhere AI use materially affects the representation, communicate with the client about the use, the limits, and the protections.

Florida Bar Opinion 24-1

Addresses when client consent or disclosure is appropriate.

Opinion 512

Addresses Rule 4-1.4 obligations regarding AI use.

Florida Rules

Rule 4-1.4.

Circuit Orders

Both orders are court-facing only and silent on client communication. The substantive obligation rests on Florida Bar Opinion 24-1, Opinion 512, and Rule 4-1.4.

Disclosure Carve-Out

Safe harbor for routine AI use

Operational requirementRoutine AI assistance does not trigger the disclosure requirement. Confirm the use stays within the carve-out and that you, not the tool, drafted and verified the filing’s substance.

Florida Bar Opinion 24-1

Does not create a disclosure safe harbor. The competence, confidentiality, and verification duties apply to routine AI use as well.

Opinion 512

Does not create a disclosure safe harbor. The lawyer stays responsible for AI-assisted work product, including routine research and editing.

Florida Rules

No routine-use carve-out. The competence and verification duties apply regardless of how AI was used in the filing.

Circuit Orders

Both AO 26-15 (section 6) and AO 2026-03-Gen (Amendment 2) (section 6(c)) carve out disclosure for AI use limited to routine legal research, retrieving authorities, cite-checking, and grammar, spelling, or clarity edits, provided the substance and content of the filing is drafted and verified by the filer.

The Full Protocol

The crosswalk shows what. The book shows how.

The crosswalk maps the requirements. Building and documenting a verification workflow that satisfies them is the next step.

The Book

Responsible AI for the Small Law Firm

The crosswalk shows what compliance looks like. Building it is the next step. Responsible AI for the Small Law Firm is the working guide to that protocol: how to write the AI governance policy, set the client disclosure language, and run a verification workflow that records who checked what, when, and how. It is written for solo and small firms without a compliance department, and it covers governance, risk, and implementation across six practice areas.

Get the Book

This resource is informational and is not legal advice. The crosswalk summarizes how the controlling authorities address each requirement; it does not reproduce them. Practitioners should verify all authorities, including current rule text and the operative circuit administrative orders, against primary sources before relying on them.

AI Compliance Crosswalk for Florida Lawyers

What changed, and what most firms still lack.

How the requirements map.

Competence with AI tools

Confidentiality of client information

Verification of citations

Verification of factual claims and conclusions

Professional language and tone

Candor to the tribunal

Supervision and human oversight

Client communication

Safe harbor for routine AI use

The crosswalk shows what. The book shows how.

Responsible AI for the Small Law Firm

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