AI and insolvency practitioners: what you can give ChatGPT

What can AI do for an insolvency practitioner?

On a copy where names are replaced with labels, generative AI (ChatGPT, Claude or Le Chat) can speed up five tasks:

• Summarizing proceedings: summarizing a report or letters, listing outstanding points.
• Preparing a report to the court: suggesting an outline, drafting a first version of the descriptive sections.
• Proofreading a petition to the juge-commissaire (the supervising judge): spotting an ambiguous sentence, an exhibit cited but missing.
• Analyzing takeover bids: comparing them on the same criteria (scope, jobs kept, conditions precedent, guarantees).
• Drafting letters to creditors and employees: replying to a request for information, explaining simply where the proceedings stand.

The labels are enough for the AI: it understands that [ORGANISATION_1] is the debtor company and [PERSONNE_4] an employee, without knowing their names.

What should you not give ChatGPT in clear?

• Raw documents: a report, a statement of claims, a staff list or a takeover bid as is.
• Documents from a conciliation or a mandat ad hoc (French out-of-court restructuring procedures): they are also subject to a specific confidentiality rule, recalled below.
• The decision: the assessment of a bid, the conclusion of a report. The AI suggests a wording; you decide.

Can an insolvency practitioner use ChatGPT without breaching secrecy?

Secrecy that covers the whole activity

The professional rules of administrateurs and mandataires judiciaires, approved by an order of July 18, 2018, subject them to secrecy under the conditions of articles 226-13 and 226-14 of the French Criminal Code (Code pénal) (rule 212.1). This secrecy covers “everything that came to the knowledge” of the professional “in the course of their activity”. Article 226-13 punishes the disclosure of secret information “by one year's imprisonment and a fine of 15,000 euros”, and the preamble of the rules warns: “Any breach exposes the professional to disciplinary proceedings” (our translation).

These texts don't prohibit AI; they prohibit disclosure. Yet a document pasted in clear into an online assistant is sent to the service provider, a third party to the proceedings.

Staff and trainees too

Under rule 213.6, the administrateur or mandataire requires staff and trainees to respect secrecy “as a contractual obligation”. Under rule 213.7, they inform them of the professional rules that concern them and keep proof of it.

A benchmark for online services

For the digital backup of the accounts, rule 530.3 already requires the professional to check the means used by the provider to “ensure the security, confidentiality and backup of the data”. It doesn't address AI, but the reflex is the same: know where the text goes, who has access to it and how long it is kept.

Prevention: conciliation and mandat ad hoc

Article L. 611-15 of the French Commercial Code (Code de commerce) adds a specific obligation: anyone called to take part in a conciliation or a mandat ad hoc, or who learns of it through their duties, “is bound to confidentiality”. Draft agreements and exchanges with the banks therefore call for particular vigilance.

GDPR: employees, creditors, managers

Employees, managers, guarantors, creditors who are natural persons: their information is personal data, relating to an “identified or identifiable natural person” (article 4 of the GDPR). Article 5 requires it to be “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed”. To summarize a report, the AI needs no names at all.

Replacing names with labels, while keeping the mapping at the office, is pseudonymization within the meaning of article 4: the data can no longer be attributed to a person “without the use of additional information”, kept separately. See the difference between anonymization and pseudonymization.

What does the CNAJMJ say about artificial intelligence?

The Conseil national des administrateurs judiciaires et des mandataires judiciaires (CNAJMJ) sets the profession's professional rules, approved by the order of July 18, 2018. That is where rule 212.1 on secrecy appears. As of October 14, 2026, we have found no public CNAJMJ guide or recommendation specific to generative AI.

Without a dedicated text, the existing rules are enough to draw the line: secrecy covers everything the practice learns, conciliation is confidential (article L. 611-15 of the French Commercial Code) and the GDPR requires sending only what is necessary. An internal AI policy lets you write these rules down for the whole practice, staff included.

What the IFPPC article says

On the website of the Institut français des praticiens des procédures collectives (IFPPC), the French association of insolvency practitioners, Charles Beaussart, administrateur judiciaire, compares the arrival of AI to that of email. Uses already possible, in his view: minutes of meetings, especially videoconferences, and a first version of certain letters. Later: financial analysis, the standard parts of reports, entering proofs of claim, multi-criteria analysis of takeover bids, summarizing the banks' positions in a conciliation.

His condition: complying with ethical obligations, “in particular regarding professional secrecy and the protection of personal data (GDPR)” (our translation). He calls on the profession to take a collective approach, with shared rules on confidentiality, security and ethics. The article doesn't say how to prepare the documents, even though its last example concerns a conciliation, covered by article L. 611-15: hence the value of sending only anonymized, reviewed copies.

What to mask in a report or a petition before AI?

Here is what to remove from a report, a petition or a statement of claims before the AI, and what AnonymFiles finds on its own.

No automatic detection is perfect, hence the review of each document. A passage masked by hand is masked throughout the file, wherever it appears in the same form. For the judgment itself, see also how to anonymize a judgment or exhibits.

Clues published in the BODACC

A copy without any names can still point to a set of proceedings. The judgment opening a safeguard (sauvegarde), receivership (redressement judiciaire) or judicial liquidation is the subject of a notice in the Bulletin officiel des annonces civiles et commerciales (BODACC), France's official gazette of civil and commercial notices. This notice states, among other things, the debtor's name, registered office or business address, unique identification number, business activity and “the date of the judgment that opened the proceedings” (articles R. 621-8, R. 631-7 and R. 641-7 of the French Commercial Code, our translation).

These notices can be consulted freely on bodacc.fr, with a search by name, SIREN number, words in the text and category, including “Procédures collectives”. They state the court, and some the case number (RG). Court, date of judgment and business activity left in clear can therefore be enough to find the notice, and the company. The same caution applies to a trading name, an establishment address or a unique job. At each review, one question: would a colleague at the same court recognize the proceedings?

Large proceedings: the whole file, the same labels

Proceedings bring together many documents: judgments, reports, petitions, orders, proofs of claim, bids, letters. Anonymized one by one, by hand, they quickly contradict each other: a creditor becomes “Bank A” here and “Creditor 2” there, and the AI loses track.

AnonymFiles processes the proceedings as a whole: you drop in the entire file, subfolders included, and the same person or company keeps the same label in every document. A label can be renamed to make it meaningful, for example [ORGANISATION_DEBITRICE].

That leaves the scans: proofs of claim received on paper, signed documents. AnonymFiles reads them by local OCR and erases the pixels of detected areas in the image. Spreadsheet statements and emails are read too. A signature or a stamp the OCR can't read is masked in one click during review; to understand what's at stake in a scan, see how to anonymize a scanned PDF.

The method with AnonymFiles, step by step

AnonymFiles is a desktop app, coming soon for Apple silicon Macs and Windows. A practice's workflow is detailed on the how it works page for insolvency practitioners; for a single document, see how to anonymize a document before ChatGPT.

1. Gather the proceedings. Word (.docx), text or scanned PDF (50 MB at most), emails, spreadsheets, .txt or .md. The originals are never modified.
2. Run detection. Names of people, organizations, addresses, emails, French-format phone numbers, IBANs from nine European countries, private dates and ID numbers become stable labels, such as [PERSONNE_1].
3. Review side by side. One click masks what detection missed: amounts, case number, trading name. You approve document by document; nothing is exported without approval.
4. Export. The copies for the AI go into a new folder: for a text PDF, a PDF with the same layout, with labeled black blocks; for a Word file, a redacted .docx with the same layout. Masked content is truly removed, not hidden under a black box that leaves the text readable; metadata, annotations, forms and links are removed; file names become neutral and an index lists the exported and excluded documents. A Word file gives a .docx redacted in place, layout preserved, plus a text copy (Markdown) for the AI: body, headers, footers and notes are processed; comments, tracked changes, hidden text, images, macros and properties are removed, never copied over.
5. Work with the AI. The “Copier la consigne IA” (copy the AI instruction) button gives the instructions to paste at the start of the conversation: keep the labels and recall the file reference, in the form [DOSSIER_…].
6. Put the names back and proofread. “Réinjecter un résultat” (re-inject a result) puts the real names back into the AI's answer, pasted or imported as .txt, .md, .docx or .pdf, on the computer, with a preview before saving. The mapping table stays on the computer, never in the export.

No account, no telemetry, no online license check. On Mac, the detection models are included: no connection at all. On Windows, they are downloaded once, on first use, without any document text. Details on the security and network perimeter page.

Pricing: €290 excl. VAT per seat per year for one or two seats, €240 excl. VAT per seat per year from three seats, on quote above twenty seats. An eight-seat practice therefore pays €1,920 excl. VAT per year. See the document anonymization software for insolvency practitioners page.

Three prompts on a pseudonymized copy

To use on a reviewed copy, once the AnonymFiles instruction has been pasted at the start of the conversation:

• Summary of a report: Summarize this report in fifteen lines: origin of [ORGANISATION_DEBITRICE]'s difficulties, employment, assets, outlook. Keep the labels exactly as they are and give the page of each item.
• Takeover bids: Compare these takeover bids in a table: scope taken over, jobs kept, conditions precedent, guarantees. Don't make up any figure and flag what is missing.
• Letter to a creditor: Write a short reply to [ORGANISATION_2], a creditor, who asks where the proceedings stand. Neutral tone, no commitment on any payment, labels unchanged.

A masked amount becomes a label, such as [CONFIDENTIEL_1]: totals and price comparisons are then done in your own tools, on the real figures.