Kobre & Kim Salary: The Posted Range (2026)

The posted floor already clears median associate-general-counsel base. The Association of Corporate Counsel 2025 Law Department Compensation Survey — 1,632 respondents, executive summary published 16 September 2025 — put U.S. associate-general-counsel median base at $245,000 and median total cash at $294,000. The 9 January 2026 floor is $260,000 of base, $15,000 above that median base, and the $294,000 total-cash median still sits $16,000 under the 2025 market fourth-year base of $310,000. A company that offers the associate-general-counsel total-cash median as if it were base has cleared the floor and has not cleared a fourth-year.

Deputy-general-counsel median base on the same survey was $280,000, which clears the posted floor by $20,000 and sits $30,000 under the 2025 fourth-year cell. Deputy-general-counsel median total cash was $368,000. That cash figure sits $22,000 under the 19 May 2026 bankruptcy cap of $390,000 and $52,000 under the January civil cap of $420,000. The cap is base. The survey’s total cash already includes bonus. A package that loses on total cash to someone else’s base has not started the conversation about the discretionary bonus the posting refuses to number. Chief legal officers at companies with revenue greater than $5 billion are the first in-house band whose median total target exceeds $1 million, per the same 2025 survey. That is the band that can absorb a $420,000 base plus a bonus the firm has not published.

The 2026 ACC Chief Legal Officers Survey, 1,049 participants, is why many companies never open the requisition. 63 percent of chief legal officers expect legal-department headcount to remain stable. Use of outside counsel was 48 percent. A conflicts-free disputes firm is built for the invoice that choice keeps outside the building. Chambers USA 2026 describes the practice as conflicts-free and limited to disputes and investigations, lists 7 ranked departments and 12 ranked individuals, and places offices in New York, Delaware, Miami, San Francisco, São Paulo, Washington, Hong Kong, Seoul, Shanghai, the British Virgin Islands, the Cayman Islands, Cyprus, Dubai, London, and Tel Aviv. The firm’s homepage prints the same city list. A general counsel who wants a cross-border investigations lawyer is not posting a generic commercial-litigation seat, and a headcount freeze does not retire the matter.

The arithmetic is the hiring problem. An attorney-grade requisition priced on the $148,000 attorney median, or a senior-attorney requisition priced on the $201,000 median, does not clear a $260,000 floor. An associate-general-counsel requisition priced on median base does not clear it either. Deputy-general-counsel cash starts a conversation with the floor and loses the cap. The $1 million large-company chief-legal-officer band is the first survey total that can carry the cap and still leave room for equity. Title is the compensation decision.

The Justice Department’s Fraud Section Year in Review for 2025 charged 265 individuals and convicted 235. Corporate enforcement was 15 actions, including 12 resolutions, the first corporate indictments from the section in over 15 years, and global monetary amounts of more than $1.01 billion, of which U.S. criminal monetary amounts were more than $553.2 million. The FCPA Unit, 22 prosecutors, described a February 2025 pause and then the June 2025 guidelines: cartels and transnational criminal organizations, harm to U.S. competitive opportunities, national security, and substantial bribe payments. The docket narrowed by design and did not go to zero. In June 2025 the same section led a health-care fraud takedown that charged 324 individuals, including 96 licensed medical professionals, with intended loss exceeding $14.6 billion.

The SEC’s own release 2026-34, issued 7 April 2026 for the fiscal year ended 30 September 2025, filed 456 enforcement actions, including 303 standalone actions and 69 follow-on proceedings, and obtained orders for $17.9 billion in monetary relief: $10.8 billion of disgorgement and prejudgment interest and $7.2 billion of penalties. The Commission then printed the adjustment a reader has to use. After excluding amounts deemed satisfied by a parallel court order, and the Stanford judgments, fiscal 2025 monetary relief was $1.4 billion of disgorgement and prejudgment interest and $1.3 billion of penalties. About two-thirds of standalone actions charged one or more individuals. The Commission obtained 119 officer-and-director bars and returned about $262 million to harmed investors. Tips, complaints, and referrals were 53,753, nearly 19 percent above the prior fiscal year. A $17.9 billion headline is in that release. Adding the two adjusted lines the Commission printed, $1.4 billion and $1.3 billion, comes to $2.7 billion. A general counsel staffing an investigations seat should budget that sum and still staff the individual-charge docket.

That mix is the company-side brief. Fewer corporate resolutions, more individual charges, a cross-border fraud emphasis, and a health-care takedown measured in billions. The lawyer who has lived on the firm side of that docket is the person a chief legal officer calls when the next inquiry arrives. The 2026 ACC survey says most departments will not add headcount to receive it. The firm’s own May 2026 bankruptcy listing, still open on the pre-July range, is the market saying insolvency disputes did not pause when the FCPA guidelines narrowed. A general counsel choosing between a deputy-general-counsel offer and another year on the panel is choosing between those two documents: the posted range, and the 63 percent who expect the roster to stay the same size.