# License agency data to AI: own records and client files

> Want to sell agency data to AI? You can license your own records. Client files sit under client contracts, so sort what you own and check buyer size limits.

By Matt Burns, Vaultfish. Canonical: https://vaultfish.com/answers/sell-agency-data-to-ai  
Published: 2026-07-24  
Updated: 2026-10-14

## The short answer

To license agency data to AI, separate the agency's own records from client files. Client files sit under client contracts and often hold confidential information covered by NDAs, so a lawyer reads those agreements first.

An agency sits on two kinds of records. Some belong to the agency, and some belong to the people it works for.

## Whose data does an agency hold?

The [Frankfurt Kurnit memo](https://technologylaw.fkks.com/post/102o455/selling-company-data-for-ai-training-what-to-know-before-you-say-yes) tells owners to review customer, partner, vendor and data license agreements and to identify data held as a service provider or processor.

My reading is that client work often falls into that second group, because agencies handle material on a client's behalf.

The agency's own records are the cleaner part: internal chat about its operations, its project tickets and its finance files. Even there, client names show up in the threads. My [rights check](/rights-check) asks whose records these are, yours or your clients'.

## Does an agency meet published size limits?

[micro1's web page](https://www.micro1.ai/data-partnerships) describes operationally mature companies with 30 or more employees, with US companies first and English-language records.

In an undated recorded forum talk, [micro1](/buyers/micro1) staff gave earlier figures of 20 full-time staff and about 1 TB of data (self-reported). That talk is history. micro1's current pages say 30 or more employees, and my [micro1 guide](/guides/micro1-data-partnership) dates both.

The lowest published staff figure I found is [Handshake AI](/buyers/handshake-ai)'s 20 full-time employees, so a smaller studio may find no buyer whose published criteria fit today.

## What if a client asks about licensing its own data?

That call is the client's, made with its own lawyer. The client's data belongs to the client, so ask before you name it to anyone, and keep its files out of any conversation with a buyer.

For your agency's own records, the [rights check](/rights-check) is a free place to start.

micro1 may pay us a referral fee if a company we introduce goes ahead with it. [How we are paid](https://vaultfish.com/disclosure)

Figure: comparison of What an agency holds: Agency records (emphasized: The cleaner place to start, Yours to check), Mixed threads (Client names inside), Client files (Client contract decides). Start with the agency's own records, and leave client files to the client's contract.

[Apply to micro1's data partnership (paid link)](https://req.micro1.ai/post/74520e8b-4673-4da5-b855-53609aaf6710?referralCode=f82e519e-5d64-4e0e-9574-760c84371cf2&utm_source=referral&utm_medium=share&utm_campaign=data_referral) · [micro1's own data-partnerships page](https://www.micro1.ai/data-partnerships)

_Paid link. [How we are paid](https://vaultfish.com/disclosure)_

_Vaultfish helps you run the process. We are not lawyers and this is not legal advice. If you need counsel who knows this area, we can point you to one._

## Sources

- [Frankfurt Kurnit memo](https://technologylaw.fkks.com/post/102o455/selling-company-data-for-ai-training-what-to-know-before-you-say-yes)
- [micro1's web page](https://www.micro1.ai/data-partnerships)