The technology builds on convergence of multimodal AI, retrieval-augmented generation, and agentic systems—tools that can reason, use other applications, and complete multi-step tasks beyond simple chat. Product tutorials and demos now show users how to create replicas by uploading images, voice files, and video. The extent to which these systems are currently in active use by major corporations, and which specific executives or companies have deployed them, remains unclear. The governance frameworks governing their use—if any exist—have not been publicly detailed.
Attorneys should monitor this development closely. As digital twins move from proof-of-concept into practical deployment by decision-makers, they create novel liability and authenticity questions. A message or commitment attributed to an executive but generated by an AI replica raises issues of actual authority, apparent authority, and potential misrepresentation. Privacy and security risks also escalate when replicas are trained on confidential communications. Companies deploying this technology should establish clear disclosure protocols, define the scope of tasks replicas can perform without human review, and consider whether existing employment law, securities regulations, and contract law adequately address communications made "as" a person by an AI system.