A notary office with two notaries, five candidate notaries and some twenty clerks and support staff handles in one week the transfer of houses, the founding of companies, marriage contracts, wills and the settlement of estates. The supplier of its office software has announced an assistant that will summarise files and draft deeds. Meanwhile one of the candidate notaries has found that a general chatbot turns a shareholders agreement of forty pages into a usable summary in a minute.
The law that governs her is short. Article 22 of the Wet op het notarisambt binds the notary to secrecy about everything he learns in his work and lays the same duty on everyone who works under his responsibility. Article 103 lists what the chamber for the notariat may impose when a complaint is well founded, among them a reprimand, a fine, suspension for at most six months and removal from office. The fine can go up to the fourth category of the criminal code, which stood at 27,500 euro on 1 January 2026. Beyond the disciplinary chamber stands article 272 of the Wetboek van Strafrecht. A person who intentionally breaches a secret he must keep by reason of his profession faces up to one year in prison or a fine of the fifth category, 110,000 euro at the same date.
The Koninklijke Notariële Beroepsorganisatie published a weighing framework in two parts in 2025. It leaves the choice of systems to the office and is firm on the conditions. The duty of secrecy may not be breached by the use of artificial intelligence. The notary must know enough about the security of a system and about what happens with the input, and where that knowledge is lacking, deciding against use is a responsible choice. The supplier is to be asked whether the system is located in Europe and also managed from Europe. There is also a test that any clerk can apply, which is whether one would share these data with people or organisations outside the office. If the answer is no, the framework says, entering them into a model that processes them further is a bad idea. On free tools that are open to everyone, it advises against use for now.
The usual response in an office like this is to wait. The professional body is developing a private cloud for the profession during 2026, meant to keep secrecy and data security within the Netherlands. Waiting does nothing about the candidate notary, whose chatbot is already a data flow that nobody has recorded. The second usual response is to accept the software supplier's statement that everything is hosted in Europe. That answers half of the framework's question. A data centre in Europe run by a company from the United States is located in Europe, and whether it is managed from Europe is for the contract to settle.
The two notaries have to decide for themselves, one kind of work at a time. Data can take three routes: the online service of a model provider under contract, a private deployment under the office's control, or a machine inside the building. One office might decide as follows. Wills, living wills and estates in which the family is in dispute never leave the building, and if a model is used on them at all, it runs on the office's own hardware. Deeds of transfer and company deeds may go to a private deployment in a European region once the contract has been checked against the framework's questions. Questions about published law and model clauses without names may go through an online service on a business contract. Free tools get no file at all.
A machine in the building removes the transfer to a third party, which is why the Council of Bars and Law Societies of Europe called it in March 2026 the most secure option for confidentiality. Every other duty stays. The General Data Protection Regulation applies to each deed on that machine. The models an office can run itself are measurably weaker than the best hosted ones, so their output needs more checking.
Whatever the routes, the same governance follows. The office keeps a register of the tools in use and the supplier's answers on file. It tries a tool on its own old deeds before anyone relies on it. It logs who used what on which file and holds to the rule that the notary reads what he signs. A personal data breach must as a rule be reported to the supervisory authority within 72 hours. Training is a legal duty of its own: the European Union Artificial Intelligence Act has required since 2 February 2025 that organisations which deploy such systems take measures to support the literacy of their staff.
On 1 January 2026 the Netherlands had 860 notary offices, and almost half of them had a single notary. The AI Guys can prepare the decision with an office and test a tool on its own deeds. By next month the two notaries should hold a single sheet with the kinds of files in one column and the permitted route in the other, signed by both, together with the supplier's written answers to the questions of part two and an instruction of half a page that every employee has read.