Salary benchmarks · United States
Associate general counsel salary 2026: the dated U.S. table
The first number a company asks is what a deputy or associate general counsel costs. The Association of Corporate Counsel and Empsight survey, data effective 1 March 2025, puts those two U.S. cells on the table. This page is that table, who writes the check, and why the seat stays open.
The first number is a cell, not a GC package.
A company that asks for associate general counsel salary in 2026 is asking what the number-two legal seat costs, not what a general counsel costs. Sartori maps some 67,000 lawyers in New York. The dated cells below are what those seats actually clear on the public instrument that prices them.
U.S. associate general counsel median base, Association of Corporate Counsel and Empsight 2025 Law Department Compensation Survey, data effective 1 March 2025, 1,632 U.S. in-house respondents. ACC / Empsight 2025 ↗
Four cells, one instrument, one effective date. The 2026 question is whether the company will clear them against lockstep and a frozen headcount. The full table is below.
- 1,049
- Chief legal officers in the 2026 ACC CLO Survey (43 countries, 20 industries), the desk a deputy or associate general counsel reports into.
- ACC Chief Legal Officers Survey, January 2026
- +75%
- Associate general counsel median total compensation at companies with $5 billion-plus revenue versus companies under $1 billion, same 2025 ACC/Empsight survey.
- ACC / Empsight 2025 Law Department Compensation Survey
- 32%
- Share of 135 large-company law departments (median revenue $13 billion) that expect attorney-headcount increases, down from 42 percent.
- Harbor 2025 Law Department Survey, 8 December 2025; CLOC 2026 SOTI
- 28%
- Counter-offer incidence on Sartori's New York in-house search line over the trailing three years.
- Sartori New York in-house mandate telemetry
The 2026 associate general counsel salary table
The Association of Corporate Counsel and Empsight International priced two job families, data effective 1 March 2025. This page owns those two rows. The general-counsel salary page owns the legal-chief package; the in-house salary guide owns the seniority ladder.
A general counsel who walks into finance with “what deputies make” is not asking for an Occupational Employment and Wage Statistics median. The Bureau of Labor Statistics May 2025 Occupational Employment and Wage Statistics table puts U.S. lawyers (SOC 23-1011) at 754,500 jobs and a mean annual wage of $185,840; O*NET, citing BLS 2025 wage data, puts the median annual wage at $159,670. Those figures describe wage-and-salary lawyers in covered establishments. They are not an associate general counsel band.
The instrument that does price the seat is the 2025 Law Department Compensation Survey Executive Summary, authored by the Association of Corporate Counsel and Empsight International, LLC, a human-resource compensation consultancy. It fielded 1,632 U.S. in-house respondents between 6 May and 27 June 2025, with an effective date of 1 March 2025. Deputy General Counsel is grouped as SVP Deputy General Counsel. Associate General Counsel groups SVP Associate General Counsel, VP Associate General Counsel, VP Associate General Counsel – Division, and VP Associate General Counsel – Business Line / Legal Specialty. Medians are reported for positions with five or more respondents; 90th percentiles for ten or more.
Total cash is base plus actual bonus, including companies that paid zero. Total target direct is base plus target short-term incentive plus target long-term incentive. Neither cell is realized stock. Google Ads Keyword Planner, four-country export dated 11 September 2026, recorded 320 U.S. monthly searches for the associate-general-counsel string this page is built on, and 210 for deputy general counsel salary — which is why the H1 follows the higher-volume cell and the table still carries both rows.
| Seat | Median base | 90th base | STI eligible | Median total cash | 90th total cash | LTI eligible | Median total target |
|---|---|---|---|---|---|---|---|
| Associate General Counsel | $245,000 | $340,000 | 93% | $294,000 | $450,000 | 59% | $338,000 |
| Deputy General Counsel | $280,000 | $371,000 | 96% | $368,000 | $514,000 | 67% | $424,000 |
Associate general counsel: STI target 25 percent, median STI $65,000, median LTI target $78,000, 90th total target $585,000. Deputy general counsel: STI target 30 percent, median STI $82,000, median LTI target $100,000, 90th total target $730,000. Same PDF. The 90th is a large-company tail, not a mid-market promise.
On the same instrument, managing attorney median total cash is $283,000 and general counsel / chief legal officer median total cash is $410,000. The deputy sits between a division GC ($341,000) and the legal chief. The associate general counsel sits between a managing attorney and the deputy. That is ladder location, not this page’s thesis. The general counsel salary 2026 page owns the chief package, including the Above the Law restatement (1 August 2025) of ALM’s 2025 ranking: median $2.95 million among 544 Fortune 1000 named-executive-officer legal chiefs. That universe is equity-heavy and almost never the deputy. The in-house counsel salary guide owns counsel through GC as a seniority walk.
Above the Law / iManage’s 2024 In-House Compensation Survey, fielded June to September 2024 and published 19–28 February 2025, put all-in-house median pay (base plus most recent cash bonus) at $300,000 among more than 1,100 attorneys, with general counsel / chief legal officer median $365,000 and junior-level counsel $181,500. It does not publish a separate AGC or DGC median. Do not interpolate one. The two instruments describe mixed public, private and nonprofit samples. They are not one average.
Who pays deputy general counsel salary in 2026
The buyer on this page is almost never a law-firm practice group. It is a company putting a lawyer on its own payroll under a sitting general counsel or chief legal officer.
A file the GC still holdsThe officer the board named
- Associate general counsel Owns a practice area or business line — contracts, employment, litigation, privacy, commercial — and usually reports to the general counsel. Often more than one at scale.
- Deputy general counsel Second-in-command. May own a region or a function. The succession bench when the legal chief retires, is promoted, or is named in a current report.
- General counsel / CLO The officer. Most report to the CEO, most overlay compliance, ethics, privacy or risk, and a majority also hold or oversee the corporate secretary function. Owned as a pay table elsewhere.
ACC describes itself as serving attorneys in the legal departments of corporations, associations, nonprofits and other private-sector organizations. The 2025 compensation sample that prices the two cells is a company mix, not a firm-practice mix. Legal-department staff of ten or more: 57 percent. Revenue of $5 billion or more: 35 percent. The deputy layer exists at the large-desk end of that mix. ACC still prices a General Counsel — Single Lawyer band; that company is buying a legal chief, not a number two.
| Buyer on the payroll | Share of the 2025 sample | What the DGC/AGC seat is |
|---|---|---|
| Private company | 43% | Operating-company legal desk under a GC or CLO |
| Public company | 42% | Item 5.02 succession bench under the legal chief |
| Nonprofit | 8% | Mission office of general counsel |
| Wholly-owned subsidiary | 5% | Division or business-line overlay |
| Government | 1% | Not the SES/GS associate-general-counsel posting |
CLOC’s 2025 State of the Industry report, drawing on Harbor’s 2024 survey, put median legal-department headcount at 77 FTEs and median attorney headcount at 44. By revenue: under $3 billion, median 13 staff; $3–15 billion, 54; $15–40 billion, 145; over $40 billion, 244. A deputy requisition is a large-desk product. Harbor’s 2025 wave of 135 departments sat at median revenue $13 billion.
The officer the deputy reports to is not a practice chair. The Society for Corporate Governance, restating ACC 2026 on 26 February 2026, put the general counsel title at 55 percent and the chief legal officer title at 34 percent (up from 25 percent in 2025). Worldwide, 84 percent of top legal officers report to the CEO; United States, 87 percent. Columbia Law School’s Blue Sky Blog, 27 February 2026, noted that those who do not most commonly report to the CFO (42 percent of the non-CEO reporters). Dual, direct reporting with the board has sat in the 52–54 percent band for several years; 79 percent almost always attend board meetings. A company hiring a deputy in 2026 is underwriting that overlay, not a securities-associate demand story.
ACC’s residual of BLS Occupational Employment and Wage Statistics, published 2025 with data through 2024, puts U.S. in-house lawyers — total lawyers minus legal-services lawyers minus government lawyers — at 145,000 in 2024, up from 78,000 in 2008. That is the sitting field inside which deputy and associate general counsel titles exist. It is not a title census. A deputy headcount cannot be read off 145,000. New York’s in-house stock in that paper moved from about 16,000 to 23,200 between 2019 and 2024. Coverage of the New York file is a different sentence: Sartori’s mapping of that market is the research program that produces the interview book, not a second count of deputies.
NALP’s Class of 2025 Selected Findings (5 August 2026) counted 2,180 business jobs, 6.7 percent of jobs, the lowest business share since the Class of 1989. In-house lawyers were 23.7 percent of those business positions. A campus-to-in-house trickle is not the deputy a general counsel underwrites. ACC/Empsight records prior law-firm experience for 77 percent of respondents; in the previous-experience bar, 16 percent went directly in-house after law school.
The letter is a mix of base, bonus and target equity, read against the hours the seat actually consumes.
- Hours cluster mid-week. ACC/Empsight 2025: average hours for all participants 47 a week. Deputy general counsel, associate general counsel, managing attorney and VP/Director Legal Operations peak in the 45-to-55 range, with averages clustering around 47-to-50.
- Stress sits on the management layer. CLOs, division GCs, deputies and associate general counsel “consistently show a higher combined percentage of high stress and severe stress, often exceeding 25 percent.”
- Prior firm experience moves cash. For associate general counsel, prior firm experience is associated with 18 percent higher median base and 20 percent higher total cash. For deputy general counsel, it is associated with a two-percentage-point lower median base and 13 percent higher total cash.
- Mobility is real and cooling. Twenty-eight percent of respondents changed jobs in the prior two years (up from 25 percent); 17 percent say they are likely to change in the coming year (down from 20 percent). Seventeen percent received a promotion. Those not promoted: average merit 3.5 percent, median 3.0 percent.
The check is written by a general counsel or chief legal officer whose own overlay is already heavier than the headcount plan.
- Revenue is the first multiplier. At companies with $5 billion-plus revenue versus under $1 billion, associate general counsel median base is 36 percent higher; deputy general counsel total compensation is 27 percent higher. LTI eligibility is greater than 50 percent at $5 billion-plus versus around 30 percent under $1 billion.
- Compliance is usually in the legal box. ACC 2026: functions most commonly overseen by the top legal officer include compliance (64 percent), ethics (41 percent), privacy (40 percent) and risk (35 percent). A deputy who “owns compliance” is answering a Department of Justice question, not decorating a title.
- Specialty premia flatten at this seniority. ACC/Empsight names higher pay in securities, antitrust, bankruptcy/creditor, pension/ERISA and government relations, and lower overall in information technology, corporate contracts and entertainment, with less variation across practice areas among more senior management-level positions.
- Outside hours are not the seat. Thomson Reuters Institute and Georgetown Law, in the January 2026 Report on the State of the US Legal Market, put average Am Law 100 standard rates through $1,000 in 2025 on a 184-firm sample. That is the invoice the sitting deputy authorizes. It is not what the company pays the deputy.
Public 2026 appointments, reduced to type, show the live path. A NYSE-listed defense contractor named its sitting deputy general counsel as successor to a retiring legal chief (Law.com Corporate Counsel, 15 July 2026); the deputy had joined from an Am Law 100 litigation seat in 2018. A private AI laboratory promoted an associate general counsel to general counsel (Law.com Corporate Counsel, 25 August 2026). University offices of general counsel ran the same internal path: a Massachusetts private research university promoted a deputy for labor, employment and dispute resolution to vice president and general counsel (employer announcement, 4 May 2026); a Louisiana private research university with an academic medical center named its deputy, in post since 2022, as general counsel effective 1 July 2026. Those are path types, not a turnover rate, and not this page’s pay table.
Federal offices of general counsel use “Associate General Counsel” and “Deputy Associate General Counsel” as division-head titles under a GC and a DGC, with a published J.D. and active-bar gate. An Executive Office of the President / Office of Management and Budget Associate General Counsel (Management and Information Branch) SES posting, open 27 April to 11 May 2026, listed $198,200–$228,000 and reported through the Deputy General Counsel. An FCC Deputy Associate General Counsel, Administrative Law, GS-15 posting, open 20 April to 21 May 2026, listed $169,279–$197,200. OPM’s Salary Table 2026-NY, effective January 2026, caps GS-15 at $197,200. The government attorney salary 2026 page owns that band as thesis. A New York company paying ACC deputy median base of $280,000 is already above that cap.
Law360, 19 May 2026, restated PitchBook: more than 9,000 active private-equity portfolio companies now span technology, industrials and consumer sectors. Preqin, data as of January 2026, put 2025 U.S. buyout deal value at $376 billion and a global overhang of companies held five-plus years at $989 billion across almost 8,400 companies held four-plus years. That is a company stock that typically staffs a portfolio general counsel and, at scale, a deputy layer. PitchBook does not count those legal seats. The Houston PE-industrial mandate story is a separate case study, not this table.
The overlay arrived. The requisition often did not.
The 2026 deputy seat stays open because headcount plans do not move with the docket, and because a matching-firm counsel will not take the ACC median base against a $385,000 lockstep floor.
The docket is heavierThe FTE line does not move
- Headcount freeze The chief legal officer keeps the department stable and uses outside counsel as the pressure valve. The overlay is real. The requisition is not.
- Lockstep gap The approved band copies last year’s attorney number. A senior matching-firm counsel is sitting on a different instrument.
- Hours instead of a seat Panels, alternative fees, and a dedicated AI committee absorb the new file. The company still needs an owner the next time a disclosure clock starts.
In Sartori’s New York interview cohort, 203 of 341 respondents sitting inside company legal departments with ten or more legal staff, over a 24-month window, told us the last deputy or associate general counsel letter they saw had been priced as a senior attorney seat with a better title.
In the same cohort, 88 of 119 New York general counsel and chief legal officers, over an 18-month window, named lockstep opportunity cost — not the ACC median — as the number that actually moved a matching-firm counsel. A general counsel at a New York-listed industrial told us the compensation committee would “do $280,000 because that is the deputy number,” then lost the first two shortlisted counsel when year-6 lockstep sat at $410,000. A head of talent at a private New York technology company said an associate general counsel requisition sat open six months because finance would not put target long-term incentive on a number-two seat, even though 59 percent of ACC AGC respondents were LTI-eligible.
ACC’s 2026 Chief Legal Officers Survey (1,049 CLOs, 43 countries, fielded September–November 2025, released January 2026) found 63 percent expect legal-department headcount to remain stable, with generative AI framed as role evolution rather than replacement (36 percent already in active deployment). Chronic budget and resource constraints were the top barrier for 35 percent; operational efficiency was the top strategic initiative for 53 percent. Outside counsel (48 percent) and consultants (27 percent) are the regulatory pressure valve. The two fastest-growing regulatory concerns already on that survey: trade and tariffs (30 percent) and AI regulation (24 percent).
Thomson Reuters Institute’s 2026 State of the Corporate Law Department Report (24 March 2026) found that nearly half of general counsel cite staffing and resource constraints as the top barrier to delivering additional value. As of the fourth quarter of 2025, 36 percent of general counsel expect to increase overall spend on outside counsel over the next year; 20 percent plan to decrease. Harbor 2025: 65 percent of departments made intentional efforts to keep work in-house in the last one to two years; 61 percent had completed or were implementing convergence or preferred-provider panels. The deputy seat is in-house. A large fraction of the work still sits at the firms the deputy panels.
ACC 2025 (772 CLOs) had already named the demand that does not wait for a requisition: litigation volume up for 42 percent; internal investigations up for 44 percent; 23 percent of organizations faced a regulatory investigation or enforcement action in the prior year. Industry-specific regulatory enforcement was the top CLO concern (72 percent), then labor and employment (37 percent) and third-party risk (35 percent). Larger companies also named antitrust (41 percent) and AI regulatory enforcement (26 percent). Fifty-eight percent were heavily involved in M&A and other corporate transactions. Thirty percent planned to increase the number of lawyers hired that year. The 2026 wave did not convert that plan into a headcount boom.
Bloomberg Law, updated 2 June 2026, reported that Milbank raised associate salaries by $10,000–$20,000 by seniority, to a new range of $235,000 to $455,000, effective 1 July 2026; McDermott Will & Schulte matched the same day. Biglaw Investor’s published 2026 scale puts year five at $385,000 and year eight at $455,000, with an eighth-year total including listed bonuses of $585,000. The 2026 BigLaw associate salary scale owns that ladder as thesis. This page uses the endpoints as the opportunity-cost row. A company hiring a year-5 matching-firm counsel into associate general counsel is bidding $385,000 of firm base against an ACC AGC median base of $245,000 — a $140,000 gap on base alone, before bonus. The dated cell is not the cost of the seat. The cost is the cell plus the lockstep the company must clear.
The committee would do $280,000 because that is the deputy number. Then the shortlist went back to lockstep.
What actually loads the AGC salary requisition
The rules that create 2026 deputy work are stacked and dated. They hire mid-to-senior in-house owners, not campus counsel, and they do not wait for the FTE line to move.
A clock the company did not chooseA file that needs an owner
- Cyber disclosure A material incident still has a public-company disclosure clock the board can see. A petition to rescind the item is a petition, not a repeal.
- Privacy and AI California privacy regulations and an AI transparency statute now bind most U.S. employers. A federal task force challenges state AI laws in parallel.
- Deals and outbound The premerger form reverted; mega-deal value did not. Outbound investment rules are a standing national-security overlay.
- Trade and investigations IEEPA ad valorem duties ended; a temporary surcharge and surviving 232/301 still run. FCPA resumed in a narrower form.
The SEC’s cybersecurity incident-disclosure rule, Release No. 33-11216 (26 July 2023), still requires Form 8-K Item 1.05 disclosure of a material cybersecurity incident within four business days of the materiality determination, with a limited Attorney General delay. Item 1.05 has been effective since 18 December 2023. A 22 May 2025 joint petition (File No. 4-856) asks the Commission to rescind it; it has not. Debevoise’s public 8-K tracker, updated 21 May 2026, counted 29 issuers with Item 1.05 filings and 50 issuers with Item 8.01 filings since the Division of Corporation Finance’s 21 May 2024 materiality statement; only five issuers used both. The hiring consequence is an associate or deputy who can run that clock and the board overlay — 2024 through 2026, and until any APA repeal.
California Privacy Protection Agency regulations under the CCPA, labeled effective 1 January 2026, put automated decision-making notices and opt-outs, risk assessments, cybersecurity audits and expanded consumer-rights procedures on top of the statute. The California AI Transparency Act (Business and Professions Code Chapter 25) is operative 2 August 2026. Covered providers, as of the chapter text, include a person that produces a generative-AI system with over 1,000,000 monthly visitors or users publicly accessible in the state. Civil penalty: $5,000 per violation per day, enforceable by the Attorney General, a city attorney or county counsel. Most U.S. deputy employers do business in California. The White House order of 11 December 2025 directed the Attorney General to establish an AI Litigation Task Force to challenge state AI laws inconsistent with a “minimally burdensome national policy framework.” An in-house AGC (privacy / product / AI governance) now runs state compliance and federal-challenge risk in parallel.
The HSR form expansion took effect 10 February 2025. The U.S. Court of Appeals for the Fifth Circuit denied the Commission’s stay on 19 March 2026; filers reverted to the form in place before 10 February 2025. Form-build hours peaked under the 2025 form, then fell. Deal hours did not. The FTC and DOJ Hart-Scott-Rodino Annual Report for fiscal year 2025 (2 July 2026) counted 2,006 transactions notified, about 31.8 percent valued at more than $1 billion, and 18 merger enforcement actions. LSEG, 12 August 2026, put United States announced M&A at US$1.69 trillion for January–July 2026, the strongest opening seven months for U.S. targets; 48 mega-deals above US$10 billion totaled US$1.29 trillion. Combination and take-private activity can retire one of two sitting legal-leadership benches, or create a first public-company deputy seat. That is a structural implication, not a hire series.
Treasury’s outbound-investment final rule, 31 CFR Part 850, published 15 November 2024, has been effective since 2 January 2025: specified U.S.-person investments into China, Hong Kong and Macau involving semiconductors and microelectronics, quantum information technologies, and artificial intelligence. As CFIUS chair, Treasury reported on 7 August 2026 a calendar-year 2025 caseload of 347 notices and declarations of covered and covered-real-estate transactions, with 67 percent of distinct transactions cleared in the 30-day declaration assessment or the initial 45-day notice review. Renaissance Capital, 8 September 2026, put year-to-date U.S. IPO proceeds at a record $146 billion ($71 billion excluding SpaceX) and 92 U.S. IPOs on file. Filing counts are not appointment counts. They are why a public-company deputy of securities, CFIUS and outbound exists.
ACC had already ranked trade and tariffs the fastest-growing CLO concern before the February 2026 orders. Executive Order 14389 (20 February 2026) terminated additional IEEPA ad valorem duties; Section 232 and Section 301 duties are expressly unaffected. A companion proclamation imposed a 10 percent ad valorem surcharge under section 122 of the Trade Act of 1974 for 150 days, effective 24 February 2026. The FCPA pause (10 February 2025, 180 days) ended in a narrowed resumption: the Deputy Attorney General’s 9 June 2025 guidelines tell prosecutors to focus on individual criminal misconduct, Cartel/TCO nexus, and national-security infrastructure. The Criminal Division’s 12 May 2025 white-collar memorandum names trade and customs fraud, including tariff evasion, among priority areas. The investigations desk does not go dark. The type of inquiry that lands on it tilts.
The U.S. Department of Justice Criminal Division’s Evaluation of Corporate Compliance Programs (updated September 2024) still asks where the compliance function is housed — inside legal, under a business function, or as an independent function reporting to the CEO or the board — and whether it has direct access to the board or the audit committee. A board that hires a deputy with a compliance overlay in 2026 is answering that question. Splitting out a chief compliance officer is the alternative seat, not the absence of work.
The dated cell is not the cost of the seat. The cost is the cell plus the lockstep the company must clear.
Base, bonus, target equity — and the 16-day clock
The lawyer who earns the figure and the general counsel who pays it are reading the same letter from opposite sides. The mix, not the title, is what either side can defend.
GS-15 New York cap (OPM 2026)
Salary Table 2026-NY, effective January 2026. Executive Schedule Level IV cap. A public-body ceiling, not a corporate DGC cell.
OPM Salary Table 2026-NY ↗For the sitting associate or deputy: compensation is rated 9.0 / 10 on importance in ACC/Empsight 2025, with the largest importance–satisfaction gap (2.7). That gap is why a letter that only copies median base fails. Short-term incentive eligibility is 93 percent for associate general counsel and 96 percent for deputy general counsel; long-term incentive eligibility is 59 percent and 67 percent. A cash-only number-two seat is off-instrument for the sample that produced the medians. Top-20 law school is associated with around a five-to-six percent base difference and a 10-to-19 percent total-cash difference at DGC and AGC — a credential premium, not a hiring rule.
For the general counsel who pays it: revenue is the lever that moves the cell before geography does. The +75 percent AGC total-compensation gap at $5 billion-plus versus under $1 billion is already on the opening grid. What finance often misses is LTI eligibility itself. Copying an attorney band into an AGC requisition, then adding a title, produces the 24-month interview read above. Sartori’s New York in-house offer-to-acceptance window is a median of 16 working days. A committee that takes three weeks to add target LTI after a verbal accept is already past that window, which is where the 28 percent counter-offer incidence on this line does its damage.
Two anonymized composites from the New York in-house book, category only. A New York-listed software issuer opened an associate general counsel (cybersecurity, disclosure, incident-response) after Item 1.05 stopped being a hypothetical. The first approved base sat on last year’s senior-attorney number. The first shortlisted matching-firm counsel declined. The file closed in month five after the company put a 25 percent STI target and a 30 percent LTI target on the letter — the AGC eligibility rates on the ACC instrument, not an invention. A national retailer with headquarters legal in New York opened a deputy general counsel (commercial, regulatory, supply-chain) against the February 2026 tariff unwind. The external slate priced above the committee. An internal associate general counsel took the seat in month seven, at the long end of the 4-to-7-month window. The search still earned its fee. It did not produce the external appointment the brief described.
ABA Model Rule 1.13 (Organization as Client) is the professional-conduct architecture both readers already live with: the lawyer employed by the organization represents the organization, not the officer who hired them. A deputy who cannot take a matter up the line is not a cheaper general counsel. They are a compliance finding waiting for a monitor. The credential gate is a J.D. plus active state-bar admission. Federal SES and GS-15 postings make that gate explicit; corporate postings assume it. Neither reader should treat a title change as a substitute for independence.
What 24 closed searches actually did with the deputy cell
Sartori has worked the New York in-house line for more than 10 years, for general counsel and chief legal officers at public companies, PE-backed operators, and university legal desks. The deputy files are a subset of that book, not a second book.
Over the trailing three years Sartori closed 24 New York in-house searches, with a 93 percent completion rate and a typical timeline of 4 to 7 months. Median offer-to-acceptance on that in-house line is 16 working days. Counter-offer incidence is 28 percent. Of those 24 files, 11 were general counsel or chief legal officer seats — owned as a hiring story by a sibling page. Of the remaining 13, 6 were deputy or associate general counsel seats the company opened after a general counsel brief had been withdrawn. The company still needed the overlay. It could not get a sitting officer to move on the original reporting line or the original cash cell. The other 7 were specialist seats around a sitting officer.
Of those 6 deputy and associate general counsel files, 3 were scoped as associate general counsel (a named file: privacy, cyber, commercial) and 3 as deputy general counsel (second-in-command). Three of the 6 closed only after the company raised the approved base to clear the ACC AGC median cell. Two closed on an internal promotion after the external slate priced above the committee. One of the 6 was withdrawn after the board froze attorney headcount with a shortlist already in motion. That withdrawn file sits inside the unsuccessful remainder against a 93 percent completion rate. It is the finding that does not flatter the method: we can fill a specified number-two seat. We cannot make a compensation committee un-freeze a headcount it has already closed.
Two of those 6 files drew a competing counter-offer before signature, inside the 28 percent incidence we record on the New York in-house line. Sartori’s mapping records title and employer. It does not reliably record whether a sitting lawyer is an associate general counsel or a deputy, because companies do not standardize the words. The 6 files were scoped by reporting line and overlay, not by the requisition’s title line. That is what our own New York file cannot see, and it is why a company that opens “AGC” at an attorney band, then wonders why matching-firm counsel will not move, is not describing a talent shortage.
Sartori’s quarterly survey since 2019 has been picking up the same mis-specification. In the 2026 Q1 wave, 11 of 16 New York general counsel who had an open associate or deputy general counsel requisition in the prior 18 months said the approved base had been copied from last year’s attorney band, not from the ACC AGC cell. Nearly 1.5 million lawyer profiles sit in the global mapping behind that program, with those quarterly waves running since 2019.
When the board decides the overlay has to sit on the payroll, in-house counsel recruiting is the product. The legal-chief package is a different table. The lockstep a matching-firm counsel forgoes is a third. This page is the dated deputy and associate general counsel cells, who writes the check, and why the requisition stays open after the overlay has already arrived.
Deputy and associate general counsel pay: common questions
What is the associate general counsel salary in the United States in 2026?
The Association of Corporate Counsel and Empsight 2025 survey, data effective 1 March 2025, puts U.S. associate general counsel median base at $245,000. Median total cash is $294,000; median total target direct compensation is $338,000. The 90th-percentile total cash is $450,000. Those cells are self-reported across mixed company sizes, not Fortune 1000 proxy totals and not realized stock. A 2026 self-report raise was not published as a public table; the 1 March 2025 cells stand.
What is a deputy general counsel salary compared with an AGC?
Deputy general counsel median base is $280,000 in the same ACC/Empsight 2025 survey, with median total cash $368,000 and median total target $424,000. DGC median total cash sits between division/subsidiary GC ($341,000) and GC/CLO ($410,000) on that instrument. AGC median total cash sits between managing attorney ($283,000) and DGC. The words on the title line are not a dictionary; scope, reporting line and overlay decide which cell a company is actually buying.
Why do companies leave an AGC or deputy seat open in 2026?
ACC's 2026 CLO Survey of 1,049 respondents found 63 percent expect legal-department headcount to remain stable. Harbor's 2025 wave of 135 departments (median revenue $13 billion) has only 32 percent expecting attorney-headcount increases, while workload is up in regulatory (63 percent) and cybersecurity (58 percent). The overlay arrives. The requisition often does not.
Does the 2026 lockstep change what a company must pay an AGC?
Yes. Milbank's scale, announced 2 June 2026 and effective 1 July 2026, runs $235,000 to $455,000. A company hiring a year-5 matching-firm counsel into AGC is bidding $385,000 of firm base against an ACC AGC median base of $245,000. That gap is a comparison of two published instruments, not a hiring conclusion. Target LTI and Sartori's New York in-house median of 16 working days from offer to signature are what close it.
Is federal Associate General Counsel pay the same as corporate AGC salary?
No. An Office of Management and Budget Associate General Counsel SES posting open in April 2026 listed $198,200–$228,000; an FCC Deputy Associate General Counsel GS-15 listing ran $169,279–$197,200. OPM's 2026 New York locality table caps GS-15 at Executive Schedule Level IV, $197,200. Those are public-body desks with a published bar gate. They are not the ACC corporate cell.
How does in house counsel salary compare with AGC and deputy pay?
On the same ACC/Empsight 2025 instrument, attorney median total cash is $160,000 and senior attorney $228,000 — below AGC $294,000 and DGC $368,000. Above the Law / iManage's 2024 opt-in survey put all-in-house median pay at $300,000 (published 19–28 February 2025) with no AGC or DGC breakout. Do not interpolate an AGC cell from a GC median and a junior median. NALP's Class of 2025 business-sector median of $100,000 is a first-job number, not this seat.
ACC/Empsight cells, CLO surveys, Harbor/CLOC, lockstep announcements, and the statutes that load the seat
Self-reported pay, department-intention surveys, lockstep announcements, and primary rules. Mandate counts are New York in-house files, not a national vacancy series.
Sources
39 references- Sartori & Partners — New York Legal Talent Research Programme (1,675 structured interviews; ~67,000 lawyers mapped; quarterly surveys since 2019; mandate telemetry) sartoriglobal.com ↗
- 2025 Law Department Compensation Survey Executive Summary acc.com ↗
- US In-house Counsel Population Statistics acc.com ↗
- 2026 ACC Chief Legal Officers Survey Key Findings acc.com ↗
- 2025 ACC Chief Legal Officers Survey Key Findings acc.com ↗
- Chief Legal Officer / General Counsel Benchmarking societycorpgov.org ↗
- New Survey Informs Board Oversight of Chief Legal Officers clsbluesky.law.columbia.edu ↗
- 2025 CLOC State of the Industry Report cloc.org ↗
- Harbor 2025 Law Department Survey Reveals Surge in AI Integration, Falling Outside Counsel Spend harborglobal.com ↗
- CLOC Releases 2026 State of the Industry Report: Rising Legal Demand Outpaces Budget and Staffing Growth, Forcing Operational Shift cloc.org ↗
- 2026 State of the Corporate Law Department Report: GCs align strategy to corporate imperatives, but C-Suites want more thomsonreuters.com ↗
- 2026 Report on the State of the US Legal Market blogs.thomsonreuters.com ↗
- Milbank, McDermott Raise Associate Salaries Up to $455,000 (1) news.bloomberglaw.com ↗
- Biglaw Salary Scale + Bonuses (1968 - 2026) biglawinvestor.com ↗
- Table 1. National employment and wage data from the Occupational Employment and Wage Statistics survey by occupation, May 2025 bls.gov ↗
- 23-1011.00 — Lawyers onetonline.org ↗
- iManage Announces Results of 2024 In-house Legal Compensation Survey Report imanage.com ↗
- Stat(s) Of The Week: Tech Tops The Charts abovethelaw.com ↗
- Final Rule: Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure sec.gov ↗
- Cybersecurity Incident Disclosure: Form 8-K Tracker (Two-Year Update) debevoisedatablog.com ↗
- California Consumer Privacy Act Regulations cppa.ca.gov ↗
- CHAPTER 25. AI Transparency Act [22757 - 22757.6] leginfo.legislature.ca.gov ↗
- Ensuring a National Policy Framework for Artificial Intelligence whitehouse.gov ↗
- FTC and DOJ Issue Fiscal Year 2025 Hart-Scott-Rodino Annual Report ftc.gov ↗
- Premerger Notification Program ftc.gov ↗
- Global M&A update: A record-breaking market that's becoming increasingly concentrated lseg.com ↗
- US Buyouts 2026: Deals, Exits, and Fundraising preqin.com ↗
- Fall 2026 US IPO Preview renaissancecapital.com ↗
- Treasury Releases CFIUS Annual Report for 2025 home.treasury.gov ↗
- Provisions Pertaining to U.S. Investments in Certain National Security Technologies and Products in Countries of Concern federalregister.gov ↗
- ENDING CERTAIN TARIFF ACTIONS whitehouse.gov ↗
- Imposing a Temporary Import Surcharge to Address Fundamental International Payments Problems whitehouse.gov ↗
- Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security whitehouse.gov ↗
- Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) justice.gov ↗
- Evaluation of Corporate Compliance Programs justice.gov ↗
- Salary Table 2026-NY opm.gov ↗
- Jobs & JDs Employment for the Class of 2025 Selected Findings nalp.org ↗
- Becoming The Biz-Savvy GC That Portfolio Companies Need law360.com ↗
- A guide to the types of Legal Counsel juro.com ↗
ACC/Empsight cells are self-reported, data effective 1 March 2025, not company-sourced HR files and not realized stock. Harbor/CLOC and ACC CLO figures are stated plans, not filled seats. Lockstep endpoints are matching-firm announcements as reported, not in-house pay. Sartori New York figures are mandate telemetry and one interview cohort for the city. ALM's Fortune 1000 legal-chief median is a ceiling the deputy sits under, not a DGC cell.
Adjacent tables and the search product
General counsel and CLO salary 2026
The legal-chief package this deputy sits under — base, bonus and equity, owned as a separate table.
Read the GC table SalaryIn-house counsel salary 2026
Counsel through deputy to GC as a seniority walk. This page is the dedicated DGC and AGC 2026 rows, not that ladder.
Read the in-house guide SalaryBigLaw associate salary scale 2026
The lockstep a company must clear to hire a matching-firm counsel into AGC — $235,000 to $455,000, effective 1 July 2026.
Read the 2026 scalePrice the number-two seat
Underwrite the deputy before the overlay arrives.
Whether you are a general counsel filling an associate or deputy seat, or a sitting counsel reading a letter, we price the New York in-house role against the dated cells and the lockstep a matching-firm counsel forgoes.