I was recently talking to the Country Manager of the Spanish subsidiary of an American multinational. He had spent months putting out legal fires without anyone at headquarters seeing what that cost him in time, and every month he had to explain on the call with the US why the legal matter in Spain still wasn’t resolved. It isn’t an isolated story. According to the data I’ve been reviewing these past few weeks, it’s a symptom of a structural shift in how mid-sized companies and subsidiaries of international groups are organising their legal advice.
A market that has doubled in two years
According to LexisNexis, by 2026 a third of lawyers in the United Kingdom could be working as legal consultants rather than as employees of a firm or a company. Within that trend, one role is growing with particular force: the External General Counsel, known as a fractional general counsel in the Anglo-American world. It is part of a broader phenomenon, that of “fractional” senior executives generally (CFOs, COOs and general counsel, among others), which according to data from FRAK, the industry’s benchmark conference, has gone from 60,000 professionals in 2022 to 120,000 in 2024. It has doubled in two years, and general counsel is one of the branches of that phenomenon standing out the most within it.
The drivers behind that growth are not a passing fad. Forbes estimates payroll savings of between 30% and 40% compared with hiring a full-time General Counsel. Korn Ferry, in a report still cited years after publication, projects more than 85 million unfilled positions globally by 2030, pushing organisations to look for senior talent through arrangements more flexible than traditional hiring. And the type of company that turns to this model most often is exactly the one I see every week: companies going through a significant moment of change — international expansion, a regulatory shift, a corporate transaction — that need board-level legal judgement without the structure of an in-house legal department.
Why this matters more in Spain than it seems
In the United Kingdom or the United States, where the legal services market has been maturing for longer, the distinction between an in-house lawyer, an outside lawyer and a “fractional” one is fairly well established. In Spain, and especially in Spanish subsidiaries of American or European groups, the problem has an extra layer: language and legal culture.
I have spent 25 years working from both sides of the table, as outside counsel and as board secretary for Spanish subsidiaries of multinationals. And the pattern repeats with a regularity that no longer surprises me. Headquarters asks for legal reports in a format the local firm doesn’t know how to produce, neither in the language nor in the structure an American General Counsel expects. A contract reviewed by a Spanish advisory firm reaches headquarters with no one there able to verify whether it truly protects the group’s interests. And when someone calls from Madrid at nine at night, three in the afternoon in New York, nobody picks up until the next day.
A recent article by the International Bar Association on this role draws a distinction I think is central: a fractional GC is not the same as an “interim” lawyer hired for a one-off project with an expiry date. It is ongoing, long-term strategic support, with the same commitment an in-house General Counsel would have, but without the cost or the rigidity of an employment contract. That is exactly the difference I draw in my own service: it isn’t a fixed contract, it’s a relationship of trust that is reviewed and adapted as the company’s needs change.
When it makes sense to consider this model
Not every company needs an External General Counsel, and the ones that do won’t need it in the same way forever. But in my experience there are signs that the moment has arrived: when the legal workload can no longer be handled through improvisation and scattered queries to different firms; when the foreign parent demands a level of governance and reporting the local advisory firm isn’t equipped to deliver in its language; when no one at the company could say with certainty whether the board minutes or the shareholder register would survive a serious audit; or simply when the cost of a large firm for routine work no longer makes sense against having a single trusted senior point of contact.
The IBA’s own report also warns of the risks of this model when poorly managed: limited availability if the professional takes on too many clients at once, loss of depth if they don’t spend enough time getting to know the company, conflicts of interest if they work for several competitors in the same sector. These are reasonable warnings, and the answer isn’t to avoid the model — it’s to choose carefully who you work with: someone with enough experience not to need to learn on the job, and with the discipline not to take on more clients than they can serve at the level of responsiveness they promise.
A trend that is not going to reverse
The experts cited by the IBA agree on something I find the most honest conclusion: “portfolio” legal careers, with several clients under a fractional model, are on track to become the norm rather than the exception. And the profile needed to do it well isn’t purely legal. Beyond the law, it demands business management skills, the ability to work across different corporate cultures, and comfort with the legal technology that today lets an independent professional offer the same level of service as an in-house legal department.
If you recognise any of the situations I describe here in your own company, or if you simply want to understand better whether this model fits the moment your company is in, let’s talk about your case. You can learn how I work in the External General Counsel service, or write to me directly for a first consultation with no obligation.
Pablo Gómez-Acebo Calonje is a lawyer (Madrid and New York), a graduate in Psychology, and founder of Estudio Jurídico Alta Mediación. He provides External General Counsel services to mid-sized companies and Spanish subsidiaries of international groups.