30-60-90 day plan for general counsel
On this page
- What makes a general counsel's first 90 days different?
- Which rules shape a new general counsel's first weeks?
- What does the 30-60-90 day plan look like?
- Which numbers should a new general counsel baseline?
- How should the CEO or board use the plan in the final interview?
- What should each check-in cover?
- A filled example
- What does the CEO and board owe the new general counsel?
- Common mistakes
- How do you adapt the plan?
- Questions people ask
A 30-60-90 day plan for a new general counsel should, in the first month, build an inventory of every open matter and legal hold, read the board record and the delegation of signing authority, and learn what the company spends on outside counsel; then own the contract process and the board reporting cycle by day 60, and present a legal risk report and an operating plan for the legal function by day 90. Two rules shape the first weeks as of October 2026: courts can sanction a party that fails to preserve electronic evidence once litigation is anticipated, and at a public company the chief legal officer receives reports of possible material violations under the SEC's attorney conduct rules.
This plan is for a CEO or board hiring a general counsel or chief legal officer, whether the company's first or a successor. The executive listening tour is in the 30-60-90 day plan for executives, and the compliance program side in the 30-60-90 day plan for compliance officers.
What makes a general counsel's first 90 days different?
A general counsel inherits risk that nobody has written down in one place. Litigation sits with outside counsel, contracts sit with sales and procurement, regulatory correspondence sits with whoever opened the letter, and the board minutes record decisions that may still bind the company. The new GC's first job is to put that on one list with owners, exposure and dates, and to find out which items have deadlines that will not wait.
The second difference is the client. The GC works for the company, not for the CEO or any one executive, and every executive will test where that line sits. Explaining it early, and saying plainly to employees in an internal inquiry that the GC acts for the company, avoids harder conversations later.
Which rules shape a new general counsel's first weeks?
As they read in October 2026; not legal advice. Industry regulators, stock exchange rules, state bar rules and the company's own charter and agreements add more.
| Area | What applies | Source |
|---|---|---|
| Preserving electronic evidence | If electronically stored information that should have been preserved in the anticipation or conduct of litigation is lost and cannot be replaced, a court may order measures no greater than necessary to cure the prejudice; if the party acted with intent to deprive, it may presume the information was unfavorable, instruct the jury so, dismiss the action or enter a default judgment | Federal Rules of Civil Procedure, Rule 37(e) |
| Reporting up (public companies) | Attorneys appearing and practicing before the SEC for an issuer report evidence of a material violation to the chief legal officer (or CLO and CEO) forthwith; the CLO causes an appropriate inquiry and reports back to the attorney | 17 CFR 205.3 |
| Compliance program expectations | Prosecutors ask whether the program is well designed, adequately resourced and empowered, and works in practice; the September 2024 version includes questions on emerging technology such as AI and on protecting whistleblowers | DOJ, Evaluation of Corporate Compliance Programs (updated September 2024) |
| In-house practice licensing | State-specific. Example: California's registered in-house counsel rule requires an active license in good standing elsewhere, residence in California, services only to the employer, no California state court appearances, State Bar registration and annual renewal | California Rules of Court, rule 9.46 |
What does the 30-60-90 day plan look like?
30-60-90 day plan — [Name], General Counsel, [company]
Reports to: [CEO] Board / committee supported: [ ]
Start date: [date] Company type: [private / PE-backed / public]
Legal team: [N] lawyers, [N] paralegals / contract managers
Outside counsel: [N] firms Next board meeting: [date]
DAYS 1-30 — Know the exposure
Goals:
- Matter inventory: every lawsuit, investigation, regulatory inquiry,
demand letter and threatened claim, with exposure, owner, next date
- Confirm every legal hold: scope, custodians notified and
acknowledged, IT preservation steps actually taken
- Read board and committee minutes for two years, charters, bylaws,
the delegation of signing authority and insurance policies (D&O,
cyber, employment practices)
- List outside counsel: matters, rates, spend for 12 months
- Meet the CEO, CFO, board chair, committee chair, each business
head, HR, the compliance officer and every lawyer on the team
- Public company: learn how up-the-ladder reports reach the CLO
Deliverables by day 30:
- Matter and hold inventory, reviewed with the CEO
- A list of dated obligations for the next two quarters
Check-in: day 30, with the CEO
DAYS 31-60 — Own the legal operating rhythm
Goals:
- Contract intake: templates, playbook, who can sign what, turnaround
- Outside counsel guidelines: budgets, staffing, billing rules
- Prepare the legal section of the next board or committee meeting
- Agree with the compliance officer on one shared risk list
- Assess the team: roles, workload, key-person risk
Deliverables by day 60:
- Board materials delivered; contract playbook in use for the
highest-volume agreement type
- Outside counsel budget for each major matter
Check-in: day 60
DAYS 61-90 — Report and plan
Goals:
- Legal risk report to the CEO and board: top exposures, actions,
reserves discussion with the CFO
- Operating plan for the legal function: team, outside counsel mix,
tools, budget
- Close or reset any matter strategy that no longer fits
Deliverables by day 90:
- Risk report delivered; operating plan approved by the CEO
Check-in: day 90 — full reviewWhich numbers should a new general counsel baseline?
The standards below are examples only. Most legal measures are counts and trends, not benchmarks; agree definitions with the CEO and CFO before reporting them.
| Measure | Why it matters | Example standard (example only) |
|---|---|---|
| Open matters by exposure band | The board's first question | Every matter banded with an owner by day 30 |
| Legal holds with custodian acknowledgment | Preservation failures can bring sanctions | All active holds confirmed by day 30 |
| Outside counsel spend against budget by matter | Usually the largest controllable legal cost | Budgets set for major matters by day 60 |
| Contract turnaround by type | What the business notices about legal | Measured for the top agreement type by day 60 |
| Contracts signed outside the signing authority | Shows whether the delegation works | Found and corrected in the day-60 review |
How should the CEO or board use the plan in the final interview?
Give every finalist the same brief: company type, the largest open matters in summary, the board calendar, team size and outside counsel spend. Score the plan with how to evaluate a 30-60-90 day plan in an interview. A strong plan starts with the matter and hold inventory and the board record, and does not promise to cut outside counsel spend before reading the matters. Scenario questions:
- "In week two a former employee's lawyer sends a demand letter alleging fraud by a sales leader. What happens in the next 48 hours?" Listen for a legal hold, who investigates, and keeping the accused executive out of the process.
- "A business head wants you to sign off on a contract today that the playbook would not allow. How do you handle it?"
- "What would you want to read before your first audit committee meeting?"
- "How do you decide which matters stay with outside counsel and which come in-house?"
The interview guide for legal roles covers the in-house loop and the confidentiality questions to ask every candidate.
What should each check-in cover?
| Checkpoint | Questions to ask | On track | Worth a direct conversation |
|---|---|---|---|
| Day 30 | "What could hurt us in the next six months?" | Matter and hold inventory complete; dated obligations listed; key people met | Working only the CEO's requests; holds assumed rather than checked |
| Day 60 | "What did the board hear from legal, and what changed in contracting?" | Board materials delivered; playbook in use; budgets for major matters | Every contract still escalated to the GC; outside counsel unbudgeted |
| Day 90 | "What is the legal function's plan for next year?" | Risk report delivered; operating plan approved | No risk report; plan is a headcount request without priorities |
A filled example
General counsel: Michael Grant (invented), previously deputy GC at a larger software company, hired as the first GC at a private-equity-backed health technology company of 600 people.
Day 30: His inventory found eleven open matters, two of them employment claims with legal holds that had been sent but never confirmed with IT, whose email retention would have deleted relevant messages within weeks. He had preservation set that week. Board minutes showed a commitment to the lenders to report any material litigation, which nobody in legal had tracked.
Day 60: Introduced a playbook for customer agreements so the two contract managers could approve standard deviations without him. Set budgets with the three largest outside firms and delivered the legal update to the board.
Day 90: Presented a risk report covering the employment claims, a data protection review of a new product and the lender reporting obligation, and an operating plan adding a privacy lawyer instead of a second litigation firm.
What does the CEO and board owe the new general counsel?
- Direct access to the board and the relevant committee chair, not only through the CEO.
- Every document: past investigations, settlements, regulator letters, insurance notices and side letters.
- A clear signing authority and a rule that legal sees certain agreement types before signature.
- Support when the answer is no, especially in the first 90 days, when executives test the role.
Common mistakes
- Assuming holds work. A hold letter without IT preservation steps is not a hold.
- Becoming the CEO's personal lawyer. The company is the client; blur that and every later investigation is harder.
- Reviewing every contract personally. Without a playbook and delegation, legal becomes the bottleneck by day 60.
- Firing outside counsel in month one. Learn the matters first; changing firms mid-case has its own cost.
How do you adapt the plan?
- Public company: add the disclosure committee, Section 16 filings, insider trading policy and the up-the-ladder reporting process; coordinate with the CFO plan on certifications.
- First GC at a growth company: expect to build templates, a matter list and outside counsel relationships from scratch; weight days 1-30 toward contracts and employment.
- Regulated industry: add the regulator relationship and examination history to days 1-30, and agree roles with the compliance officer early.
- GC who also owns security incidents: agree the notice-clock table with the CISO; the CISO plan describes it.
Questions people ask
What should a new general counsel do in the first 30 days?
Build an inventory of every open matter (litigation, investigations, regulatory inquiries, disputes and threatened claims) with its exposure, owner and next date; confirm every active legal hold is in place and acknowledged; read the board minutes, committee charters and the delegation of signing authority; list outside counsel with their spend; and meet the CEO, CFO, board chair, the chair of the committee the GC will support, and the heads of the largest business units.
Does a general counsel need to be licensed in the state where the company is based?
Rules differ by state. Many states let lawyers licensed elsewhere work as in-house counsel if they register. California, for example, has a registered in-house counsel rule (California Rules of Court, rule 9.46) under which the lawyer must be an active licensee in good standing of another U.S. jurisdiction, live in California, provide legal services only to the employer, not appear in California state courts, register with the State Bar and renew annually, as of October 2026. Check the rule in the state where the GC will work; this is not legal advice.
What duties does a public company's chief legal officer have under SEC rules?
Under 17 CFR Part 205, as of October 2026, an attorney appearing and practicing before the SEC for an issuer who becomes aware of evidence of a material violation must report it to the chief legal officer, or to the CLO and the CEO, forthwith. The CLO must then cause the inquiry they reasonably believe appropriate and, if they find no material violation, tell the reporting attorney why. A new GC at a public company should know how such reports reach them in week one.
How is a general counsel's 30-60-90 day plan different from a compliance officer's?
A compliance officer's plan centers on the compliance program: risk assessment, policies, training, the hotline and monitoring. A general counsel's plan covers the company's legal exposure as a whole: open matters and legal holds, contracts and signing authority, outside counsel and spend, the board and governance, and the legal team. In many companies the compliance officer reports to the GC, so the plans should share one risk list.