European CLOs face higher investigation costs, ACC survey finds

Forty percent of European Chief Legal Officers (CLOs) have reported increased costs due to internal investigations, 11% higher than the global average of 29%, according to the 2025 ACC Chief Legal Officers Survey. The report, released by the Association of Corporate Counsel (ACC) in partnership with FTI Consulting, highlights key differences between European and global legal departments in terms of costs, priorities, and regulatory challenges.

Investigations and Costs

The survey shows that 58% of European CLOs have seen a rise in internal investigations, compared to 44% worldwide. This has contributed to the 40% of European CLOs who reported increased costs associated with these investigations, outpacing the global average.

Reporting Structure and Strategic Priorities

The survey also highlights differences in reporting structures. In Europe, 73% of CLOs report directly to the CEO, slightly below the global average of 79%. Among those who do not report to the CEO, 59% of European CLOs report to the CFO, a figure significantly higher than the global 44%.

Regarding strategic priorities, 42% of European CLOs rank operational efficiency as their top priority, 7% higher than the global average. In contrast, talent management, data security, and litigation defensibility are more prominent priorities for CLOs in other regions.

Regulatory Challenges and External Counsel Reliance

Regulatory uncertainty is the top challenge for European CLOs, cited by 33% of respondents. This differs from the global trend, where understaffing is the most significant concern.

Additionally, more than half (53%) of European CLOs have increased their reliance on outside counsel in the past year, exceeding the global average.

Maria Barros, President of ACC Europe Chapter and Chief Legal and Public Affairs Officer at Booking.com, commented on the findings: “I was not surprised to see that in Europe the biggest challenge is regulatory uncertainty. This is in line with the Draghi report. Companies in Europe are struggling with fragmented regulation, lack of guidelines, and inconsistent enforcement. Against this backdrop, in-house teams play a key role in helping companies that want to stay compliant navigate this uncertainty.”

The ACC CLO global survey can be found here. The European-supplemental data can be found here.

flavio.caci@lcpublishinggroup.com

SHARE