What is the simplest AI compliance setup for a 10-50 lawyer Spanish despacho?+
For a firm with 10-50 letrados, the realistic minimum is four documents and one named owner, not a 12-FTE compliance department. The four documents: (1) an AI Acceptable Use Policy — what tools lawyers can use, what data categories can leave the perimeter, when a matter requires the on-prem or zero-retention tier, and which prompts always require partner authorization; (2) an AI Register following the EU AI Act Article 26 deployer logic — one row per AI system in active use (the matter-management copilot, the document-extraction tool, the marketing chatbot), tagged with risk tier under Article 6, owner, data category, and vendor DPA reference; (3) a Cliente-Notice Annex appended to the engagement letter when AI will be used materially on the matter, satisfying the informed-consent expectation ICAM and the CGAE have signalled; (4) a quarterly review checklist that touches AEPD's automated-decisions guidance, AI Act log retention, and Esquema Nacional de Seguridad alignment if the firm handles public-sector matters. The named owner is usually the Director de Cumplimiento or, in firms without one, a senior partner with explicit time carved out — typically 4-6 hours per month, not a full role. Anything more elaborate at this scale becomes shelfware; anything less leaves the firm exposed in a colegio inspection or a client audit.