Fractional General Counsel
by Rory O’Keeffe | Principal Fractional General Counsel | SCL-accredited IT Lawyer | Author, AI Advantage (2025), 6 April 2026
THE MODEL
What a fractional general counsel actually does
The title causes some confusion. A fractional general counsel is not a part-time solicitor or a legal helpline. It is a senior lawyer - typically with 15 to 25 years of commercial legal experience, usually at partner level in private practice, in-house at a significant business, or both - who works with your organisation on a flexible basis rather than as a full-time employee.
The distinction from a traditional law firm engagement matters. When you instruct a law firm on a matter, you are buying matter-specific advice. A solicitor who does not know your business, your commercial priorities, or your risk appetite picks up your file, does the work, and moves on. The fractional GC model is the opposite of this. Your fractional GC becomes embedded in the business. They attend board meetings, review commercial relationships, provide strategic input on transactions in progress, and are available between matters - not just when something goes wrong.
The IBA describes the model as combining ‘in-house proximity with specialist external expertise’. That is an accurate summary. You get a lawyer who thinks like a business partner, not a service provider billing by the six-minute unit.
What a fractional GC does day to day:
• Reviewing, negotiating and closing commercial contracts
• Advising on regulatory compliance obligations - EU AI Act, GDPR, DORA, sector-specific regulation
• Providing strategic legal input at board and executive level
• Managing and coordinating external counsel on specialist matters
• Drafting and maintaining legal playbooks, contract templates and internal governance frameworks
• Supporting fundraising rounds, M&A processes and due diligence
• Acting as a legal sounding board for the CEO, CFO and leadership team
• Covering capacity gaps when in-house legal resource is overstretched or absent
THE REAL COST
What a fractional general counsel costs in the UK - and what you are comparing it against
The cost question is the one most businesses ask first and most providers answer vaguely. Here is a direct answer.
A full-time General Counsel in the UK commands a base salary of between £120,000 and £250,000 depending on seniority and sector. Add employer National Insurance at 15%, pension contributions, private medical insurance, bonus and other benefits, and the true employer cost reaches £175,000 to £310,000 per year. That is before the recruitment fee, which for a senior hire typically runs between 20% and 30% of first-year salary. And before the three to six months it takes to hire, onboard and get a new GC up to speed on your business.
The fractional model eliminates every one of those additional costs. You are engaging a limited company contractor. There is no employer NIC. No pension obligation. No statutory leave. No recruitment fee. No onboarding period - a good fractional GC should be operationally useful within days, not months.
| Cost element | Full-time GC | Fractional GC |
| Base salary | £120k – £250k / year | Not applicable |
| Employer NIC (15%) | £17,250 – £36,000 / year | None |
| Pension (3%) | £3,600 – £7,500 / year | None |
| Benefits / medical | £5,000 – £15,000 / year | None |
| Recruitment fee | £25,000 – £75,000 (one-off) | None |
| Onboarding / ramp time | 3 – 6 months | Days |
| Total year-one cost | £175,000 – £310,000+ | Engagement-dependent |
| Typical fractional retainer | N/A | £3,000 – £12,000 / month |
The right comparison is not fractional GC fees against a law firm's hourly rate. It is fractional GC fees against the fully loaded cost of a senior in-house hire. Against that benchmark, the model typically delivers a 50 to 70 percent saving at equivalent seniority - with the added advantage of flexibility to scale up or down as your business requires. Fractional GC retainers in the UK typically range from £3,000 to £12,000 per month depending on scope and seniority, compared to a true employer cost of £175,000 to £310,000 per year for a full-time General Counsel
WHO NEEDS ONE
Five signals that your business needs a fractional general counsel
The fractional GC model is not right for every business at every stage. Here are the five situations where the case for engaging one becomes compelling.
1. You are closing bigger deals without senior legal support
The contract that adds £500,000 of annual recurring revenue is not the moment to rely on a junior solicitor or a contract review tool. Commercial agreements at scale - SaaS licensing, outsourcing arrangements, technology partnerships, distribution agreements - require a lawyer who has sat on both sides of the negotiating table on deals of comparable complexity. When the counterparty has a seasoned GC and you do not, you are exposed.
2. Your regulatory environment is getting more complex
The EU AI Act, GDPR, DORA, NIS2 and the broader digital regulatory landscape are not administrative burdens that can be managed with occasional external counsel. They require ongoing legal oversight embedded in your operations. If your business uses AI in any commercial capacity, operates in financial services, handles personal data at scale, or has European customers, you are already in a regulated environment that demands senior legal engagement.
3. Your in-house team is overstretched
The most common catalyst for engaging a fractional GC is not absence of legal resource - it is insufficiency of it. A single in-house solicitor managing a growing business’s full legal workload is a risk, not a solution. A fractional GC augments that team, handles specialist work outside their expertise, and provides senior cover during periods of high volume.
4. You are preparing for a significant corporate event
Fundraising rounds, M&A transactions, international expansion, and major outsourcing programmes all create concentrated periods of high legal demand. A fractional GC can be engaged specifically for these events - managing external counsel, leading on due diligence, structuring the transaction, and ensuring the business is protected at a moment when the stakes are highest.
5. You cannot yet justify a full-time hire but you need the capability now
This is the most common scenario for scale-ups and high-growth businesses. The business is past the stage where founders can manage legal risk alone, but not yet generating the revenue that justifies a £200,000 annual salary commitment. The fractional model bridges exactly this gap - providing full GC capability at a cost that is proportionate to the current stage of the business.
THE AI DIMENSION
Why AI governance makes the fractional GC model more valuable, not less
Every business we speak to is either deploying AI tools, evaluating them, or being asked by clients and counterparties to account for how they are used. The legal implications of that shift are not marginal. They are central to commercial risk management in 2026.
AI contracts require entirely different provisions from standard commercial agreements. Liability for AI hallucinations and collisions. Ownership of model outputs and training data. Audit rights. Compliance warranties linked to the EU AI Act. Change notification obligations. These are not standard commercial law clauses - they require a lawyer who understands the technology, the regulatory framework, and how those provisions function under pressure.
The EU AI Act introduces obligations that most businesses have not yet fully mapped. Prohibited AI practices have been enforceable since February 2025. High-risk AI system obligations apply from 2 August 2026. Many businesses will discover that their HR software, fraud detection tools or customer scoring systems are classified as high-risk under the Act — and that their vendor agreements do not currently give them the rights they need to comply.
A fractional GC with genuine AI law specialism - not a commercial lawyer who has added AI to their service list - provides exactly the oversight that businesses navigating this landscape need. This is the specific capability gap that most generalist fractional GC providers cannot fill.
“AI is not the risk. AI without oversight is.”
— Rory O'Keeffe, RMOK Legal
WHAT TO LOOK FOR
How to evaluate a fractional general counsel - the questions most businesses do not ask
The fractional GC market has grown rapidly. Quality varies enormously. These are the questions worth asking before signing an engagement letter.
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The best fractional GCs have operated at senior level in both private practice and in-house environments. Private practice builds technical depth. In-house experience builds commercial judgment. A lawyer who has only ever worked in one of those contexts brings a partial perspective. Ask specifically: what is the largest transaction they have personally led? How many deals have they closed at comparable scale to your own? Have they managed external counsel - or only been external counsel?
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A fractional GC who has spent 20 years in employment law is not the right fit for a technology business navigating the EU AI Act. Specialism matters. If AI governance, digital regulation or technology contracting is central to your legal risk profile, your fractional GC should have demonstrable, current expertise in those areas - not a one-page description of AI services added to their website in 2024.
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Some fractional GC providers are platforms - they introduce you to one of a pool of lawyers. Others are individual practitioners offering direct access to a named senior lawyer. These are fundamentally different propositions. The value of a fractional GC is built on continuity, institutional knowledge of your business, and personal trust. A platform that can switch your lawyer is not offering the same thing, regardless of how it is described.
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If your fractional GC is providing legal advice, they should be regulated by the Solicitors Regulation Authority. This is not merely a technical point. SRA regulation means professional indemnity insurance, a complaints procedure, compliance with the SRA Code of Conduct, and the ability to escalate to the Legal Ombudsman if things go wrong. An unregulated legal consultant provides no comparable protection. Always check SRA registration before engaging.
HOW IT WORKS
Fractional general counsel at RMOK Legal
RMOK Legal is led personally by Rory O'Keeffe - former Partner at Matheson, a top-tier European law firm, and former Director of Legal Services at Accenture, where he managed a team of senior lawyers handling over £2 billion in annual contract value across more than 40 industries. Every engagement is led directly by Rory. There is no junior team, no platform, no handoff. You get 20 years of senior commercial and technology law experience applied directly to your business.
Where engagements require additional capacity or specialist expertise - whether that is a complex piece of contentious work, a specialist regulatory matter, or a transaction requiring additional senior resource - Rory draws on a network of senior lawyers and boutique law firms contracted to RMOK Legal. This means clients benefit from the continuity and commercial judgment of a single trusted lawyer, with the ability to scale legal resource around specific needs without having to brief an entirely new firm from scratch.
That specialism in AI governance, EU AI Act compliance and technology contracting is not a service line added to meet market demand. It is where Rory's career has been pointing for a decade - from criminal law in Dublin, through corporate, construction, engineering, arbitration and technology, to the AI regulatory landscape that is now reshaping every commercial relationship. He sits on the AI Committee of the Society for Computers and Law, holds SCL accreditation as a Leading IT Lawyer, and is the author of AI Advantage: Thriving Within Civilisation's Next Big Disruption (2025). He also built and runs a business himself - which means when he advises on commercial risk, he understands what is actually at stake.
“A safe pair of hands on our most complex commercial deals.”
— Fortune 500 Technology Client
“Rory O'Keeffe goes the extra mile and is always focused and pragmatic.”
— Legal 500 UK, Information Technology 2023
Common questions about fractional general counsel services in the UK
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A law firm provides matter-specific external advice. When you instruct a firm, a solicitor who does not know your business picks up your file, completes the work, and moves on. A fractional GC becomes embedded in your business - attending board meetings, building institutional knowledge of your commercial priorities and risk appetite, and providing ongoing strategic input rather than reactive matter-by-matter advice. The result is faster decisions, fewer surprises, and legal counsel that operates as a genuine business partner rather than an external service provider.
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Fractional GC arrangements in the UK typically range from approximately £3,000 to £12,000 per month on retainer, depending on the scope, frequency and seniority of the engagement. This compares to a true employer cost of £175,000 to £310,000 per year for a full-time General Counsel when salary, employer National Insurance, pension, benefits and recruitment fees are included. Project-based and ad hoc arrangements are also available for businesses that need senior legal support for specific transactions or events rather than ongoing coverage. At RMOK Legal, pricing is transparent and agreed at the outset of the engagement.
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Yes - though the quality of that advice varies significantly depending on the lawyer's actual specialism. The EU AI Act is a technically complex regulation with specific obligations for providers and deployers of AI systems. High-risk obligations apply from 2 August 2026. A fractional GC with genuine AI law expertise will conduct an AI systems inventory, classify your tools against the Act's risk framework, review your vendor agreements for compliance gaps, implement governance documentation and oversight mechanisms, and advise on the contractual provisions your AI agreements need. A generalist fractional GC who has added AI to their service offering recently is unlikely to deliver the same depth. At RMOK Legal, AI governance and EU AI Act compliance is a core specialism, not a service addition.
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It depends on the stage and the nature of the legal risk. Very early-stage businesses - pre-revenue, with simple corporate structures and no significant commercial agreements - may not yet need a fractional GC. A startup that is closing its first significant commercial contracts, dealing with investor agreements, managing IP, or operating in a regulated sector has genuine need for senior legal input, and the fractional model is usually more appropriate than either a full-time hire or ad hoc external counsel. The critical question is not the size of the business but the complexity of the legal risk it is managing.
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Five things in order of importance. First, their actual experience - specifically the scale of transactions they have personally led and their depth in the areas of law relevant to your business. Second, whether they offer direct access to the senior lawyer or route work through a team or platform. Third, their regulatory status — they should be SRA-regulated. Fourth, their specialism: if AI, technology or digital regulation is central to your risk profile, choose a lawyer with current, demonstrable expertise in those areas. Fifth, their commercial judgment - a good fractional GC makes legal advice usable by business people, not just technically correct.
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At RMOK Legal, the process starts with a free 30-minute discovery call where we assess your legal needs, identify the most pressing risks and establish whether the engagement is the right fit. From there, an engagement letter can typically be agreed and in place within a week. Unlike a full-time hire - which involves three to six months of recruitment, notice period and onboarding - a fractional GC engagement can be operational within days of agreement.
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This is one of the most common use cases. In-house legal teams in growing businesses are frequently under-resourced relative to the volume and complexity of legal work they are asked to manage. A fractional GC can supplement that team in three ways: covering capacity during high-volume periods or when a colleague is absent; providing specialist expertise in areas outside the existing team's skillset - AI governance, complex cross-border transactions, or specific regulatory regimes; and providing senior strategic input when the existing team does not have a lawyer at General Counsel level. The engagement is designed to complement, not replace, internal capability.