Am Law 100 2026: Revenue, PEP and Headcount Table

Association of Corporate Counsel published its 2026 Chief Legal Officers Survey Key Findings on 29 January 2026. Thirty-four percent of respondents used the title Chief Legal Officer; 84 percent reported to the CEO, up from 79 percent in the 2025 survey; 79 percent almost always attend board meetings. Twenty-seven percent increased use of consultants to handle regulatory complexity. AI regulation was a fastest-growing regulatory priority, at 24 percent. The resource-mix shares — stable headcount, more outside counsel, GenAI, budget as barrier, operational efficiency as the top initiative, trade and tariffs — sit in the bars below. They are CLO-reported. They are not ranking FTE.

That is a pressure-valve survey, not a headcount boom. The 2025 ACC CLO Key Findings, from 772 participants, had already recorded 43 percent of chief legal officers planning to increase work sent to law firms in 2025, up 17 percentage points year on year, with 43 percent attributing the plan to the global regulatory landscape. Thirty percent planned to hire more in-house lawyers. The 2026 wave shows the outside-counsel valve still open and the in-house headcount mostly frozen. A New York general counsel reading this table is deciding which hours stay on the 100, not whether the legal department will double.

Thomson Reuters Institute and Georgetown Law’s 2026 Report on the State of the US Legal Market, dated 7 January 2026 and covering 184 U.S. firms including 50 from the 100, is the other half of that decision. In the second half of 2025, midsize firms saw nearly 5 percent demand growth while the 100 “couldn’t crack 2 percent,” and average lawyer standard rates at the 100 were cracking the $1,000 barrier while others averaged around $600. Reuters, writing up the same report on 7 January 2026, restated that split. General counsel, the report said, were shifting routine and some moderately complex work to firms charging in many cases 40 percent less. The desks that still clear the premium rate are the ones this table’s PEP is underwriting: large-cap M&A, private equity, funds, private credit, high-stakes litigation and the regulatory matters a board will not send down-market.

In that New York interview cohort, 247 of 428 general counsel, chief legal officers and heads of legal at companies that retain firms in the 100 — a 24-month window inside that cohort — said they still send bet-the-company M&A and high-stakes litigation to those platforms but have already moved routine hours to midsize firms. The public report and the private interviews point the same way. The table is not emptying. The easy hours are leaving it.

Two public appointments in 2026 show the other company-side use of this table: hiring the chair off it. On 12 February 2026, Law.com Corporate Counsel reported a NYSE-listed national aggregates company naming an Executive Vice President, General Counsel and Corporate Secretary from co-chair of global mergers and acquisitions at a New York firm in the 100, to join in March 2026 — a first in-house seat, after a prior outside-counsel relationship. On 16 April 2026 the same publication reported a global bank naming a Global General Counsel from chair of a securities and financial-services department at a Washington/Boston firm in the 100. The lawyers are not named here. The pattern is: the buyer who pays the row sometimes puts the chair on payroll.

Bloomberg Law, citing Citi on 17 August 2026, put first-half 2026 demand (billable hours) up 4.2 percent against the same period of 2025, with industry revenue up 11.7 percent, total expenses up 9.7 percent and AI spend at 0.25 percent of revenue at year-end 2025 against 0.11 percent at year-end 2024. Hours were still rising. Generative AI was a line item, not a headcount cut. Thomson Reuters and Georgetown, in the January 2026 report, still had 90 percent of legal dollars on the hour, with technology spending up nearly 10 percent and talent costs up 8.2 percent versus 2024.

The antitrust clock sat inside the same fiscal year. The updated Hart-Scott-Rodino form took effect on 10 February 2025. A U.S. district court in Texas vacated it on 12 February 2026; the Fifth Circuit later stayed Chamber of Commerce v. FTC through 31 December 2026, Latham’s 28 May 2026 alert reported, and the Premerger Notification Office went back to accepting the pre-2025 form. DOJ and FTC’s FY 2025 HSR report, issued 2 July 2026, counted about 31.8 percent of filings valued over $1 billion, 18 merger enforcement actions and, per Skadden’s 26 August 2026 write-up of that report, 41 Second Requests (2.1 percent of adjusted filings) against 59 / 3.0 percent in FY 2024. Settlements were about 40 percent of FY 2025 challenges against about 6 percent in FY 2024. Fewer trials. More remedy partners. The junior-hours burden of the vacated form is a 2026 staffing relief, not a 2025 P&L event. On 23 July 2026 DOJ said the Antitrust Division was returning to targeted Second Request investigations.

The political clock hit the same platforms. A Presidential Memorandum of 20 January 2025 froze hiring of federal civilian employees; OPM’s implementing memo the same day set the offer-and-start rules. NALP’s Class of 2025 findings put federal employment down 37 percent year on year. Executive Order 14237 of 14 March 2025, published 90 FR 13039, directed agencies to suspend security clearances, limit official engagement and refrain from hiring employees of Paul, Weiss, Rifkind, Wharton & Garrison without a waiver. Reuters reported on 11 April 2025 that nine firms had pledged about $940 million in pro bono to administration-approved causes that day, with Kirkland, A&O Shearman, Simpson Thacher and Latham at $125 million each; Perkins Coie, WilmerHale, Jenner & Block and Susman Godfrey sued. A general counsel buying government-facing hours off this table in 2025 was also buying that split: settled access, or constitutional litigation against the United States.

McDermott Will & Emery and Schulte Roth & Zabel closed a combination on 1 August 2025 as McDermott Will & Schulte, Reuters reported: about 1,750 lawyers, combined 2024 revenue above $2.8 billion. The 2026 ranking is the first full-year print for the combined name. Bloomberg Law on 14 November 2025 reported the platform fielding inbound interest in a managed-services split around non-lawyer ownership rules — a professional-responsibility conversation about partner-capital calls, not a client-matter hiring wave, and still preliminary as of February 2026.