OpenAI lists in-region model processing for ChatGPT Enterprise in Europe, the US and the UAE, not Australia.
Content sent through ChatGPT's external integrations, including the new legal plugins, is handled under each provider's own terms.
Australian regulators have told firms using commercial AI tools with client information to review the contractual terms carefully.
SYDNEY, 30 September 2026. Australian law firms adopting OpenAI's new legal tools risk treating a US launch as an Australian compliance answer, according to Quillio founder Samuel Junghenn, with OpenAI's own documentation showing Australian client material still can't be processed onshore.
"Astra for Law is a serious product built for American lawyers," said Mr Junghenn, founder and CEO of Australian legal AI company Quillio. "Australian firms should read the headlines, then read the fine print. A legal research tool that doesn't know Australian law is a very good US tool."
OpenAI's documentation lists Europe, the United States and the United Arab Emirates as the only regions where ChatGPT Enterprise keeps model processing in-region. Australian workspaces can store data locally, but not process it locally.
"OpenAI will process a UAE firm's data in the UAE. It won't process an Adelaide firm's data in Australia," Mr Junghenn said. "That may change. Today, it's the answer, and every firm putting client files into it should know that."
"Plenty of corporate and government clients require their data to stay in Australia," he said. "A firm running those files through offshore processing may be breaching its own engagement terms without realising it."
"The plugins are the part I'd worry about. The moment a lawyer connects their practice management system, the client's file is travelling under another company's terms. Most firms won't have read them."
Australian regulators have already told firms using commercial AI tools with client information to review the contractual terms carefully.
"Sending data offshore isn't automatically a breach. Not knowing where it went is the problem," Mr Junghenn said. "If a client asks where their file was processed and the firm can't answer, that's a confidentiality problem."
"No-training was never the question," Mr Junghenn said. "The regulators asked where the client's information goes and who can reach it. A US launch doesn't answer that for an Australian client."
"I'm not telling anyone to avoid ChatGPT. I'm telling them an enterprise badge isn't a confidentiality assessment. Ask every vendor the same questions, including us."
Quillio's discussion paper, Enterprise AI Is Not a Privilege Guarantee, sets out ten questions firms can put to any AI vendor: https://quillio.au/docs/enterprise-ai-is-not-a-privilege-guarantee.pdf
ENDS
Notes to editors
Claims about OpenAI's products are drawn from OpenAI's Astra for Law announcement and its help article "Data residency and inference residency for ChatGPT", as at 30 September 2026. The regulators' position is from the December 2024 joint statement of the Law Society of NSW, the Victorian Legal Services Board and Commissioner and the Legal Practice Board of WA. Samuel Junghenn and COO Bec Robertson, a dual-qualified lawyer, are available for interview.
About us:
Quillio is an Australian-owned legal AI platform built by lawyers and used by more than 230 law firms across Australia and New Zealand. It is the official AI training partner of the ACT Bar Association and holds ISO 27001 and SOC 2 Type II certification. Its security and data-handling position is published at security.legalassistant.au. quillio.au
Contact details:
Samuel Junghenn, Founder and CEO, Quillio
[email protected] | 0402 680 779
