OpenAI Is Retiring Custom GPTs: What Law Firms, Legal Professionals and Litigants in Person Need to Know

1. What is OpenAI actually changing?

A custom GPT is a version of ChatGPT configured for a particular purpose. Its creator can add detailed instructions, reference files, selected tools and, in some cases, connections to external services.

For example, a legal professional might create a GPT which follows their preferred structure for client correspondence. Another might use it to apply an evidence-review checklist. Someone representing themselves in court might rely on a GPT designed to explain procedure or help organise a chronology.

OpenAI intends to retire this particular form of customised assistant and transition creators towards plugins.

What is a plugin?

In OpenAI’s newer system, a plugin can bring together:

• Skills: reusable instructions telling ChatGPT how to approach a particular task;
• Reference files: documents and supporting material used within that workflow;
• Connected apps: access to external services, where supported and authorised; and
• Additional capabilities: tools or integrations supported by the plugin and the user’s account.

A plugin is therefore not necessarily a direct copy of a custom GPT. It can be more closely integrated with other working tools, but that also means its behaviour, permissions and technical dependencies must be understood.

Custom GPTs are not the same as ordinary chats or Projects

These are important distinctions. Someone using an ordinary ChatGPT Project to manage documents should not assume that the retirement of custom GPTs means their Project is closing.

OpenAI continues to document Projects as a separate feature. See its official guidance on Projects in ChatGPT.

2. The important dates

OpenAI’s current guidance identifies the following milestones. The Enterprise dates are planned dates and may be revised.

Important: The Enterprise creation cutoff should not automatically be treated as the deadline for every personal account. The transition affects ChatGPT plans generally, but account-specific migration access and notices may differ.

For firms and other organisations, I would recommend setting an internal migration and testing target well before December. This is a practical business-continuity recommendation, not an additional deadline imposed by OpenAI.

3. Will your conversations, files or work disappear?

This is perhaps the most important question for people who have been using AI over many months.

Existing conversations

OpenAI expressly states that existing conversations with custom GPTs will remain accessible after retirement. It says users do not need to take action solely to preserve those conversations.

That is reassuring. It should not, however, be interpreted as a guarantee that an AI chat is an appropriate permanent repository for legal records.

If a conversation has helped produce a witness statement, chronology, advice note or draft submission, the final approved material should exist in your proper records system, subject to confidentiality and retention requirements.

Instructions and reference documents

Under OpenAI’s planned migration process, the custom GPT’s instructions become a skill within the replacement plugin. Its knowledge files are copied into the plugin’s reference files.

There is one important qualification: migration uses the latest published version of the GPT, not unpublished draft changes.

Creators should therefore review their instructions and finalise essential changes before migrating. Publishing the GPT for this purpose does not require making it publicly available.

Custom actions and external integrations

This is where additional work may be necessary.

A custom GPT may have been configured to communicate with an external system through a custom action. For example, a bespoke action might retrieve information from a database or perform an operation in another application.

OpenAI says custom actions do not transfer automatically.

A replacement may require a supported connected app or a separately rebuilt integration, potentially involving a custom MCP server and technical configuration.

Any new integration needs appropriate authorisation, security assessment and testing. Similar functionality should not be assumed merely because a new connection has been configured.

Sharing and access permissions

Migration does not automatically carry over the original GPT’s sharing settings. The replacement plugin starts private.

A solicitor who created a GPT for colleagues may therefore need to arrange access to the replacement separately. Similarly, a litigant in person using a publicly available GPT cannot assume the creator’s replacement plugin will automatically be available.

4. How do you migrate a custom GPT?

If you created the GPT, OpenAI’s guidance says that when migration is available for your account, you should open My GPTs and select Migrate to plugin.

Review the migration information and follow the instructions provided in the product.

For legal use, I would recommend adding the following safeguards to that process.

1. Confirm ownership: Identify the account or workspace in which the GPT was created.
2. Record its purpose: Document the tasks for which it is currently used.
3. Review instructions: Check the latest published configuration and any unpublished amendments.
4. Identify knowledge files: Record their names, versions, provenance and any confidentiality restrictions.
5. Identify integrations: Establish whether the GPT uses custom actions or other connected systems.
6. Use safe test material: Prefer hypothetical or appropriately sanitised examples rather than identifiable client records.
7. Migrate when available: Follow OpenAI’s account-specific process.
8. Inspect the replacement: Check instructions, reference files and available tools.
9. Test its behaviour: Compare familiar outputs with those generated by the replacement.
10. Review permissions: Establish who can install, use, edit and share the plugin.
11. Approve operational use: Do not rely on it for important work until material differences have been addressed.

If the migration option does not appear, it may not yet be available for your account. It may also be disabled by your workspace or you may be signed into an account other than the one in which the GPT was created.

A person who merely uses somebody else’s GPT does not acquire the right to migrate it.

OpenAI’s Plugins in ChatGPT guide explains how plugins and their connected apps work.

5. What law firms and legal teams should do now

For a law firm, this should be treated as a controlled technology transition.

It does not necessarily require an expensive replacement project. It does require a clear understanding of which systems are being used, by whom, for what purpose and with what information.

Create a register of AI workflows

Record the custom GPTs used in the practice and identify:

• The purpose of each GPT and the team responsible for it.
• The creator and account in which it is held.
• Whether it is used for live client matters.
• The types of information it can access.
• Its reference documents, templates and instructions.
• Any connection to email, cloud storage or practice-management systems.
• The people who depend on it.
• The intended replacement and any available fallback.

In larger organisations, this work should involve the relevant legal, IT, data-protection and information-security functions.

Review the risk of individual account ownership

One easily overlooked risk is a critical practice workflow owned entirely through an individual’s personal account.

If that person is absent, leaves the organisation or no longer has the necessary access, the practice may discover that an important assistant cannot be migrated or maintained in the way it expected.

Practices should establish ownership and continuity arrangements for business-critical tools before the transition.

Test before rolling out

A successful migration does not necessarily mean an identical system.

OpenAI expressly cautions that a migrated plugin may respond differently. For legal purposes, this makes testing essential.

Use representative but non-confidential tasks to verify whether the replacement follows the intended instructions, retrieves the correct material, produces usable documents and handles connected tools properly.

Where a function can alter external records or send information, it should receive particular scrutiny.

Maintain human approval over consequential actions and preserve an alternative procedure if the tool fails.

6. What sole legal practitioners should do

For sole practitioners, the concern may be more personal. A custom GPT may represent months of refining instructions, templates and preferred methods of working.

That work has value, and it need not be discarded.

Start by identifying the GPTs you genuinely rely upon. You may find that only one or two are business-critical.

Preserve reusable instructions, checklists and templates in a secure, independent location where you are entitled to retain them. Keep client-specific records within your approved matter-management arrangements.

Then test the replacement using familiar examples. If your GPT simply helped organise research or draft correspondence, migration may be relatively straightforward. If it performed actions in an external service, you may need to rebuild or temporarily suspend that function.

Most importantly, do not leave the transition until you have a filing deadline, a client conference or a hearing the following morning.

7. What litigants in person need to know

I want to address litigants in person separately because the practical circumstances can be very different.

Someone managing their own Family Court proceedings may be dealing with years of messages, allegations, orders, reports, safeguarding concerns and deadlines. An AI assistant may have become a valuable way of imposing some order on that information.

Losing access to a familiar tool can feel particularly unsettling when you are already overwhelmed.

However, it is important to distinguish between losing access to a configured assistant and losing the underlying case.

First, identify what you actually use

Are you using a custom GPT created for a particular purpose, or an ordinary conversation within ChatGPT or a Project?

If you are using an ordinary ChatGPT Project, this particular announcement does not say your Project is being retired.

If you use someone else’s custom GPT, check whether its creator is providing a replacement. You cannot automatically migrate another person’s GPT yourself.

If you created your own GPT, follow OpenAI’s migration process when it becomes available for your account.

Second, make sure your case does not depend on one AI tool

Keep the following in a secure document store that you control:

• Sealed court orders and hearing notices.
• Documents filed with or served on the court and parties.
• Original evidence and relevant metadata.
• Correspondence with the court and professionals.
• Your chronology and evidence register.
• A separate list of outstanding tasks and deadlines.

An AI-generated summary can be a useful working aid, but it must not replace the original document.

The distinction between a draft and a filed document is especially important. Something written in a ChatGPT conversation has not thereby been filed or served.

Third, continue working from your court orders

The retirement of a software feature does not suspend a court order, extend a filing deadline or alter the procedural obligations of a party.

If your tool becomes unavailable, use the original documents and the directions made by the court. Seek appropriate procedural or legal assistance where necessary.

For further guidance, see JSH Law’s practical guide to using ChatGPT as a litigant in person.

Charities and litigant support organisations

Organisations recommending public GPTs to service users should also review their guidance.

Check whether the creator can provide a replacement and whether intended users will have access to it. Do not assume that a replacement plugin will be available on the same terms or to the same people.

Maintain a non-AI route for people who cannot access, afford or safely use a particular platform. Access to justice should not depend on one technology provider.

8. The legal responsibilities do not change when the technology changes

OpenAI’s announcement is a product development. It does not amend English law, the duties owed by legal professionals, the rules governing confidential information or the court’s requirements concerning evidence.

In fact, the migration is a useful opportunity to review how artificial intelligence is being used in legal work.

The SRA’s August 2026 warning

On 17 August 2026, the Solicitors Regulation Authority published a warning notice concerning misuse of AI.

The notice identifies particular concerns about inaccurate or invented legal material and the inappropriate handling of confidential client information.

It makes clear that solicitors and SRA-regulated firms remain responsible for professional standards when using AI. Human oversight and appropriate safeguards remain essential.

These duties are not discharged simply by choosing a paid platform, migrating an existing tool or relying on a product’s description as specialist legal technology.

Judicial accountability and verification

The judiciary published a new Position Statement on the Judicial Use of Artificial Intelligence on 9 October 2026.

It confirms an approach which is cautious but positive about AI adoption. Its principles emphasise judicial independence, security, fairness, human oversight and the responsibility of judicial office holders for decisions and material produced in their name.

Different obligations apply to judges and practitioners, but the underlying lesson is consistent: AI can assist human work without displacing human accountability.

The High Court’s judgment in Ayinde v London Borough of Haringey; Al-Haroun v Qatar National Bank [2025] EWHC 1383 (Admin) is also an important reminder of the consequences that can follow when false authorities are placed before a court.

Legal research, citations, quotations and procedural claims should be checked against reliable primary sources. A newly migrated plugin should not be assumed to be more accurate simply because its technology is newer.

Data protection and client confidentiality

The UK GDPR and Data Protection Act 2018 remain relevant wherever personal data is processed.

Depending on the use, legal organisations must consider appropriate lawful processing, data minimisation, security, transparency, supplier arrangements, access permissions, retention and the handling of particularly sensitive information.

A data-protection impact assessment may be required where processing is likely to result in high risk.

The fact that information is handled through a plugin does not establish that it is secure, confidential or suitable for a particular legal purpose.

Consider whether a connected app can access email, cloud documents, client records or other sensitive systems. Review the actual permissions, contractual safeguards and data flows before use.

The Information Commissioner’s Office publishes guidance on AI and data protection.

Particular risks in Family Court proceedings

Family proceedings frequently concern information of exceptional sensitivity.

Documents may identify children, protected addresses, schools, medical conditions, allegations of domestic abuse, safeguarding assessments and details of private family relationships.

The Family Procedure Rules, including Part 12 and Practice Direction 12G, regulate the communication of information in children proceedings.

Permission to communicate information to an adviser or another person for a specified purpose does not automatically authorise uploading that information to any external AI service.

Before uploading identifiable court documents, consider the applicable order and procedural restrictions, lawful disclosure, the service provider’s data handling, security controls and whether the upload is necessary at all.

Where these matters cannot be satisfactorily resolved, do not upload the material. Use fictional examples, appropriately sanitised test documents or a secure process that has been properly assessed.

These issues are relevant whether a user works with a custom GPT, a plugin, a ChatGPT Project or another AI product entirely.

9. A practical migration and continuity checklist

A good migration process should be proportionate. The objective is not to create unnecessary administrative work but to prevent avoidable disruption.

Step one: identify what matters

• List the custom GPTs you use.
• Confirm which ones you created.
• Identify those involved in live legal work.
• Record key instructions and reference material securely.
• Identify connected apps and custom actions.
• Record who needs access to the replacement.

Step two: establish a safe alternative

• Keep original legal documents outside the AI assistant.
• Maintain independently accessible templates and checklists.
• Identify how important tasks will be completed manually if necessary.
• Ensure deadlines remain recorded in an independent diary or case-management system.
• Do not rely on AI-generated summaries as the only available record.

Step three: test the replacement

The JSH Law six-question check

A practical review framework, not a statutory legal test.

1. What task is the AI workflow actually performing?
2. What information does it receive, and is that use permitted?
3. What source material supports its output?
4. What has changed between the GPT and its replacement?
5. Who is responsible for checking and approving the result?
6. What happens if the technology fails or produces an inaccurate result?

If those questions can be answered clearly, you have made meaningful progress towards a controlled and defensible transition.

10. Three examples of what this looks like in practice

The following scenarios are illustrative.

Example A: A small family-law team

The team uses a custom GPT containing approved letter templates and internal drafting instructions.

Its creator migrates the published version to a plugin, checks the reference files, tests the output against fictional case material and confirms which colleagues have permission to use the replacement.

Client-facing correspondence remains subject to professional review.

Result: The established method can continue, subject to successful testing and appropriate governance.

Example B: A sole practitioner with an external integration

A GPT has been configured with a custom action that retrieves documents from an external system.

Its instructions and reference files migrate, but the custom action does not.

The practitioner temporarily retrieves documents directly through the authorised system and uses the new plugin only for functions that have passed testing.

Result: Work continues while the external integration is separately assessed and rebuilt if appropriate.

Example C: A litigant in person approaching a hearing

A parent has been using somebody else’s public custom GPT to understand unfamiliar court terminology.

On learning that the GPT will be retired, the parent checks for information from the creator, retains their own lawful procedural notes, and works from the original sealed orders and case documents.

They do not assume that the creator’s replacement plugin will be available or that their court deadlines have changed.

Result: The parent can continue preparing their case without making a particular GPT indispensable to the court process.

11. Frequently asked questions

Is ChatGPT closing in December 2026?

No. OpenAI’s announcement concerns the planned retirement of custom GPTs, not ChatGPT itself.

Does this affect every ChatGPT plan?

OpenAI says the transition affects all plans, although migration availability, plugin permissions and applicable notices may vary.

Will I lose existing custom GPT conversations?

OpenAI says those conversations will remain accessible after retirement. Ordinary account access, retention and deletion rules still apply.

Are ChatGPT Projects being retired?

That is not what this announcement says. Projects are a separate feature for organising conversations, reference material and instructions.

Why can’t I see the migration option?

It may not yet be available to your account, plugins may be disabled, or you may be using a different account or workspace from the one where the GPT was created.

Can I migrate somebody else’s GPT?

Not merely because you use it. Migration is generally for the creator, with additional administrative permissions in certain workspaces.

Will my migrated plugin behave exactly like my GPT?

Not necessarily. OpenAI expressly recommends testing the replacement, including its reference material, instructions and integrations.

Will everyone who used my GPT have access to the replacement?

No. Migration does not automatically transfer sharing permissions. The new plugin starts private and access must be arranged separately.

Do I need to pay someone to rebuild my GPT?

Not automatically. OpenAI is providing a migration process where available. Straightforward instruction-based workflows may be manageable by their creator, while complex custom integrations may require technical assistance. Check availability, permissions and any relevant charges before committing to a solution.

Should I upload my Family Court bundle to test a new plugin?

No, not as a default. Use hypothetical or appropriately sanitised material for testing. Any use of real court documents requires separate consideration of confidentiality, court restrictions, lawful processing and security. Redaction alone may not eliminate those risks.

12. The wider lesson for the legal profession and access to justice

This announcement raises a question larger than the retirement of one software feature.

How do we use rapidly changing AI systems in a profession which depends upon continuity, reliability, confidentiality and accountability?

For lawyers, the answer must involve proper oversight, accurate records, careful supervision and a willingness to test tools before relying upon them.

For litigants in person, the answer must also take account of cost, accessibility and the reality of preparing a case without a professional team.

Technology can reduce some of that burden. It can help somebody identify important documents, prepare a chronology, organise questions and understand a complex process.

But it must never become the only place where their case exists.

The transition from custom GPTs to plugins is an opportunity to make our working methods more portable, auditable and resilient.

It is also a reminder that meaningful access to justice does not come from an AI system alone. It comes from people being able to understand their rights, organise reliable evidence, participate fairly and obtain appropriate assistance when they need it.

My advice is straightforward: do not panic, do not rush an untested migration, and do not abandon a useful system simply because the technology is changing. Preserve your evidence, preserve your method, check the replacement and retain human responsibility.

Official sources and further reading

OpenAI documentation

• Custom GPT Retirement and Migration FAQ.
• Plugins in ChatGPT.
• Projects in ChatGPT.
• Data Controls FAQ.

Legal and regulatory sources

• Solicitors Regulation Authority: Misuse of AI warning notice, 17 August 2026.
• Judiciary: Position Statement on the Judicial Use of AI, 9 October 2026.
• Ayinde and Al-Haroun [2025] EWHC 1383 (Admin).
• Family Procedure Rules, Part 12.
• Practice Direction 12G: Communication of Information.
• Information Commissioner’s Office: AI and Data Protection Guidance.

Related JSH Law guidance

• How to Use ChatGPT as a Litigant in Person.
• The Legal AI Trust Test: Seven Checks Before Relying on AI in Court.
• Your Family Court Case Needs a System: CRM, AI and Evidence.
• AI Agents and the Family Court: A Guide for Litigants in Person.