WORK · 2026-09-07 · 7 min

The first pass, before the consultant

Retainers are for judgement. Status checks, scope questions and cross-market deltas should not wait for a kickoff call. How to split the work.

Consultants are not the enemy of this product. They are the reason it exists. Judgement calls, strategy, a reading of what an authority will actually do: that is human work, and it is expensive because it should be. What should not be expensive is finding out whether a substance is still listed, who the duty-holder is, and whether market B added a language duty that market A did not.

The common failure is sending both kinds of work to the same invoice. The first week of a retainer is often reconstruction: associates restating annexes you could have had on Tuesday. By the time judgement starts, the clock has already run.

What belongs on your desk first

  • Status: is it listed, restricted, authorised, expired, under review.
  • Scope: does the instrument actually cover this product, this form, this use.
  • Duty-holder and deadline: who notifies, by when, under which article.
  • Cross-market delta: where the next territory diverges from the rule you already have.

Each of those has a right answer in a text, or a documented silence. They are research. They are not strategy. Doing them in-house, with cites a consultant can trust, makes the later conversation shorter and less performative.

What to hand over

Hand over the question, the cites, the trail, and the gaps. Do not hand over a cleaned narrative that hides the misses. A consultant who cannot see what you could not find will spend their time finding it again, or worse, will treat your silence as a negative finding.

The test is the same as for any internal answer. Can they open the paragraph without calling you. If they can, you have done the first pass. If they cannot, you have written a briefing, and they will start from zero.

Use both

Run the research yourself, then bring your specialist the judgement calls. RegAffairs AI does the research half.