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Twelve legal frameworks — India, UAE, UK, EU, US, Canada and China

For corporates and in-house teams

One agreement. Twelve legal systems. One review.

A contract drafted under English law has to work in India, in Germany, in the UAE. That is not translation and it is not find-and-replace — mandatory rules differ, enforceability differs, and a civil-law code supplies by default what a common-law contract must spell out in full.

Converts between

  • India
  • United Arab Emirates
  • Singapore
  • United Kingdom
  • European Union
  • Switzerland
  • Israel
  • Türkiye
  • South Korea
  • United States
  • Canada
  • China

Twelve legal frameworks

The same agreement, wherever it has to work

This is the part that is genuinely hard, and the reason the engine exists. Carrying a contract from one legal system into another is not translation and it is not find-and-replace: mandatory rules differ, enforceability differs, and a civil-law code supplies by default what a common-law contract must write out in full.

  • India

    Common law

    Court formats, stamp duty and registration, the Limitation Act 1963, and the statutory corpus a practice here actually touches.

  • United Arab Emirates

    Civil law, with common-law financial free zones

    Onshore civil code alongside the DIFC and ADGM common-law zones — one country where the answer genuinely depends on which framework the contract sits in.

  • Singapore

    Common law

    Where a great many Indian groups hold their offshore structures and where their disputes are seated. Common law, so a clause converts cleanly from an English-law source — the work is in the statutory overlay, not the tradition.

  • United Kingdom

    Common law

    England & Wales, Scotland and Northern Ireland treated as the separate jurisdictions they are, not as one.

  • European Union

    Civil law

    Union-level instruments over member-state codes, where a civil code supplies by default what a common-law contract has to spell out.

  • Switzerland

    Civil law

    Where the money and the arbitration clause both end up. Outside the EU, so EU instruments do not reach it; the banking, financing and security documents behind a cross-border deal are routinely Swiss-law, and so is the seat when neither side will accept the other’s courts.

  • Israel

    Mixed — common law over civil-law codes

    A hybrid system: common-law procedure and precedent sitting over codified civil law, which makes it one of the harder corridors and a useful test of whether an engine is really mapping concepts rather than matching templates. Heavy technology and defence contracting with Indian counterparties.

  • Türkiye

    Civil law

    A civil code adapted from the Swiss one, so the tradition maps cleanly, while the mandatory provisions and the commercial code are distinctly Turkish. It also has a rule most conversions forget: Law No. 805 requires Turkish companies to keep certain commercial contracts in Turkish, which makes the language a matter of enforceability rather than convenience.

  • South Korea

    Civil law

    A German-influenced code with a commercial act over it and a layer of mandatory protections that override what the parties agreed — a contract can be word-perfect and still not say what it appears to. Semiconductor, automotive and shipbuilding supply agreements with Indian counterparties, where the terms of art do not survive a general translation model.

  • United States

    Common law, federal and state

    Federal law over state law, because for most commercial agreements the state is the operative jurisdiction and the federal layer is the constraint.

  • Canada

    Common law, with a civil-law province

    Federal law over provincial, and Quebec on the Civil Code while the rest of the country is common law — a split that changes the answer inside one country.

  • China

    Civil law

    The Civil Code, with terms of art resolved through a legal glossary before any translation model is allowed near them.

A clause with no equivalent in the target system is reported as exactly that. "No equivalent" is a real answer, and an engine that quietly invents one is more dangerous than an engine that says so.

How a conversion runs

Six steps, and a per-clause answer at the end of each

A multinational’s agreement drafted under English law has to work in India, or Germany, or China. That is not translation and it is not find-and-replace: mandatory rules differ, enforceability differs, and civil-law codes supply by default what common-law contracts must spell out.

  1. 01

    Segment

    The source document is split into clauses at the boundaries a lawyer would recognise.

  2. 02

    Bind

    Each clause is classified and bound to a jurisdiction-neutral concept from a working ontology of commercial agreement concepts.

  3. 03

    Plan

    Each concept is mapped against the target framework as direct, partial, absent, prohibited, or implied by code — which decides what happens to the clause.

  4. 04

    Convert

    Retain, redraft, add, delete — or flag as having no equivalent in the target system, which is a real answer and not a failure.

  5. 05

    Verify

    A compliance pass over mandatory clauses, prohibited terms and formalities — stamp duty, registration, notarisation, execution requirements — as versioned data, not code.

  6. 06

    Explain

    Per clause: what changed, why, which target provision drives it, what risk remains, and what a qualified local reviewer still has to look at.

Six problems

What cross-border legal work actually costs you

None of these are AI problems. They are the ordinary friction of running one agreement through several legal systems, and they are where the money goes.

  • The same contract, redrafted from scratch in every market

    Outside counsel in each jurisdiction, each starting from your English-law template and each producing something slightly different. The conversion engine does the first pass across all of them from one source, so local counsel review a draft that already accounts for their law instead of writing one.

  • Nobody can say what changed, or why

    Every converted clause carries what changed, which target provision drove it, what risk remains, and what still needs qualified local review. A redline against the source is one of the export formats, not a favour someone does afterwards.

  • A clause that simply has no equivalent

    It is flagged as having none. "No equivalent in the target framework" is a real answer that a lawyer can act on — and an engine that quietly invents one instead is more dangerous than an engine that says so.

  • Formalities that void the agreement if missed

    Stamp duty, registration, notarisation and execution requirements are checked as versioned compliance data rather than hardcoded rules — because they change, and a rule buried in code is a rule nobody updates.

  • Terms of art mangled by translation

    Per-jurisdiction, per-language glossaries resolve terms of art before any general translation model is allowed near them. "Consideration" is not a word you let a translation API guess at.

  • Procurement and InfoSec stop the deal

    Envelope encryption with per-tenant keys, MFA, role-based access control, data residency options, and a written data-flow note covering what is stored, where, for how long, and which third parties see it.

Procurement

What an enterprise review actually tests

These are the questions that decide whether legal software gets deployed, and they have very little to do with the demo.

A structural review gate

A conversion cannot reach final status without a sign-off recorded against a named, qualified reviewer. Not a checkbox in a workflow — a state the document cannot leave without it.

Tenancy enforced below the API

Every document, job and file is scoped to your organisation at the repository layer. A resource belonging to another tenant is indistinguishable from one that does not exist.

Costs you can attribute

A cost ledger priced per model call, per organisation — so the number in the finance conversation is a measurement rather than an estimate.

Retention as a policy object

Documents and extracted text carry retention policies that a worker actually enforces, deleting the stored object as well as the database row.

Integration

Inside your own systems

Legosphere Factory is API-first. Your CLM, your intake tool or your contract repository calls it; your users never see us.

Engine details
  • Job-based generation and conversion — enqueue, stream progress, receive a signed completion callback
  • HMAC-SHA256 webhook signatures over the raw body, with the timestamp inside the signed payload
  • Idempotency keyed on normalised input, so a retried request does not bill or convert twice
  • Per-organisation quotas and seat management
  • DOCX, PDF, redline-against-source, annotated and bilingual exports, with numbering fidelity preserved

How a rollout goes

One corridor first, marked by your own counsel

  1. 01

    One corridor

    Pick the pair that costs you most today — England & Wales into India, say. We convert a real agreement of yours end to end.

  2. 02

    Your counsel marks it

    Local counsel in the target jurisdiction reviews the output as they would a junior’s draft, and tells us where it is wrong. That is the only assessment worth having.

  3. 03

    Widen the corridors

    Remaining jurisdictions on the same model, with the clause ontology and compliance rules extended per corridor rather than rebuilt.

  4. 04

    Wire it in

    API into your existing systems, with the security posture agreed before the second team is added rather than after.

Send us one agreement and the jurisdiction it has to work in

We convert it, annotate every clause, and hand it to your local counsel to mark. That is a harder test than a demo and a more useful one.

Get in touch

Got questions?
We answer them ourselves.

No chatbot, no ticket queue. Tell us what you are trying to do and someone who has worked on the software will reply.

info@legosphere.com

Please keep client names and the facts of a live matter out of this box — it is an ordinary enquiry form, not a privileged channel.