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Practice noteSecurities & capital marketsMarch 18, 2026

How an AI-native firm runs a 20-F

Where advanced AI technology actually saves time in a foreign private issuer's annual report — and where it deliberately doesn't. A look at the workflow behind a fixed-fee 20-F.


A 20-F is mostly assembly and mostly predictable: the same items, the same exhibits, the same reconciliation points every year. That predictability is why the traditional model — associate teams rebuilding the document by hand, billed by the hour — overcharges for it, and why it is the work an AI platform handles best. Here is how the engagement actually runs.

What the platform does

  • First-pass drafting from your own record. The prior 20-F, the audited financials, board materials, and the year's disclosure events go in; a marked draft comes out, section by section, with every change tied to its source.
  • Consistency checking at document scale. Numbers against the financial statements, defined terms against usage, cross-references against targets — the class of error that consumes associate hours and still slips through.
  • Comment-letter awareness. Drafts are checked against current SEC review themes for the industry, so recurring staff comments are addressed before filing rather than after.

What the lawyers do

The judgment work does not move. A partner calibrates risk factors against what actually changed in the business; decides how MD&A should characterize a difficult year; works through control conclusions with the auditors; and signs off on every page that leaves the firm. AI does the heavy lifting; a named partner owns the outcome. Nothing files on model output alone.

Why the fee can be fixed

Because the assembly layer is no longer priced by the hour, the engagement can be scoped and priced before work begins — one annual fee covering the 20-F, 6-K furnishings through the year, and ongoing securities advisory. The number is on the pricing page; it does not change mid-year because the work ran long.

What clients should take from it

If your annual report is built by hand from last year's Word file, you are paying for reconstruction, not judgment. Ask any firm — including ours — three questions: what does the software actually produce, what does a senior lawyer personally review, and is the fee committed before the work starts. The answers tell you whether "AI-enabled" is a workflow or a brochure word.


Insights are general information for discussion — not legal advice — and do not create an attorney-client relationship. Each note reflects the law as of its date; confirm current status before acting.

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