NLRB.
National Labor Relations Board (INDEPENDENT). No published AI policy for representative practice as of May 2026.
NLRB AI policy status. #
The NLRB administers the National Labor Relations Act and adjudicates unfair labor practice charges and representation cases through its administrative law judges and the Board itself. Representative practice (by attorneys and union representatives) is governed by 29 CFR Part 102. As of May 2026, no published AI policy applies to representative AI use in NLRB proceedings.
Authoritative source: https://www.nlrb.gov/
Last verified: . If this row text disagrees with the linked source, the source controls.
Why NLRB matters. #
NLRB practice is moderate-volume and politically consequential — policy direction reverses with administrations. The Board issued approximately 1,200 published decisions in fiscal year 2024; ALJ-level initial decisions number several thousand. Major recent doctrinal shifts that compound AI verification difficulty include Lion Elastomers (2023) on social-media employee speech and Stericycle (2023) reframing the workplace-rule analysis under Boeing Co.; both reversed prior Board law within four years. AI use by NLRB counsel is concentrated in brief drafting, witness-statement summarization, and analyzing the General Counsel's prosecutorial-discretion patterns through the GC memorandum series.
Practice implications. #
Representatives appearing before the NLRB should: (1) treat ABA Op. 512 as the persuasive operating reference; (2) apply enhanced verification to AI-generated NLRB precedent — the body of Board law is large, internally cross-referencing, and frequently overturned, which compounds AI hallucination risk; (3) check internal NLRB guidance memoranda (GC memos) separately from the case-law base — these are operationally controlling for prosecutorial decisions but are inconsistently reflected in commercial AI training data; (4) coordinate AI policies with the representative's home-state bar rules. The NLRB Office of the General Counsel has issued AI-related operational guidance for internal NLRB attorney work; GC memoranda are public, worth monitoring, and historically have been the precursor to formal Board-level rulemaking.