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Agents Vs. Agentic AI: What In-House Counsel Need To Know About These 2 AI Frontiers – Above the Law

Artificial
intelligence
(AI)
continues
to
reshape
industries,
from
logistics
to
health
care,
but
with
this
transformation
comes
a
steep
learning
curve
for
in-house
legal
teams.
Two
key
concepts

AI
Agents
and
Agentic
AI

are
central
to
navigating
the
legal
challenges
and
opportunities
this
technology
presents.
While
both
terms
describe
AI
applications,
their
distinctions
are
critical
when
crafting
governance,
compliance,
and
liability
strategies.

Here’s
a
breakdown
of
what
these
terms
mean,
how
they
differ,
and
the
key
legal
issues
that
in-house
lawyers
should
prioritize.


The
Basics:
AI
Agents
Versus
Agentic
AI

AI
Agents
are
task-focused
tools
designed
to
automate
repetitive
processes
or
execute
predefined
instructions.
They
do
not
make
independent
decisions
but
instead
operate
within
the
parameters
set
by
developers.
Examples
include
a
chatbot
handling
basic
customer
service
inquiries
and
tools
like
Gmail’s
Smart
Compose,
suggesting
responses
based
on
context.

In
contrast,
Agentic
AI
is
far
more
autonomous.
These
systems
perceive
their
environment,
reason
through
complex
scenarios,
make
decisions,
and
adapt
over
time.
Unlike
AI
Agents,
Agentic
AI
does
not
require
constant
human
input
to
function.
Examples
include
autonomous
vehicles
navigating
traffic
in
real-time
and
AI
cybersecurity
systems
detecting
and
mitigating
threats
without
manual
oversight.

Think
of
AI
Agents
as
rule-followers
and
Agentic
AI
as
problem-solvers.


Why
The
Distinction
Matters

For
in-house
lawyers,
distinguishing
between
these
AI
types
is
not
just
semantics

it
informs
how
you
assess
risks,
ensure
regulatory
compliance,
and
allocate
liability.
Here’s
why:


  • Operational
    Scope.

    AI
    Agents
    typically
    perform
    predictable,
    low-risk
    tasks,
    while
    Agentic
    AI’s
    autonomy
    introduces
    complexities
    like
    unexpected
    outcomes
    and
    evolving
    behavior.

  • Liability.

    When
    an
    AI
    Agent
    makes
    an
    error,
    it’s
    usually
    easy
    to
    trace
    responsibility
    to
    its
    operator
    or
    developer.
    With
    Agentic
    AI,
    which
    learns
    and
    adapts,
    pinpointing
    fault
    is
    far
    more
    challenging.

  • Compliance.

    Regulatory
    frameworks,
    such
    as
    the
    EU
    AI
    Act,
    often
    impose
    stricter
    requirements
    on
    autonomous
    systems
    (Agentic
    AI)
    due
    to
    their
    higher
    risk
    profiles.

Understanding
these
differences
ensures
that
your
legal
strategies
are
tailored
to
the
type
of
AI
in
question.


Real-World
Applications
And
Legal
Concerns


AI
Agents
In
Practice


  • Customer
    Support.

    AI-powered
    chatbots
    streamline
    support
    but
    can
    raise
    issues
    like
    inaccurate
    responses
    or
    biased
    interactions.
    Legal
    teams
    must
    ensure
    compliance
    with
    consumer
    protection
    laws.

  • Personal
    Assistants.

    Tools
    like
    Alexa
    and
    Siri
    perform
    helpful
    but
    limited
    tasks.
    Data
    privacy
    concerns
    are
    prevalent,
    as
    these
    systems
    often
    handle
    sensitive
    user
    data.


Agentic
AI
In
Practice


  • Health
    Care.

    Agentic
    AI
    systems
    analyze
    complex
    medical
    data
    to
    assist
    in
    diagnoses.
    Errors
    could
    lead
    to
    malpractice
    claims,
    raising
    questions
    about
    liability
    and
    standard
    of
    care.

  • Autonomous
    Vehicles.

    These
    systems
    operate
    independently,
    often
    making
    life-and-death
    decisions.
    Liability
    for
    accidents
    is
    a
    major
    legal
    gray
    area,
    implicating
    manufacturers,
    developers,
    and
    possibly
    regulators.


Top
Legal
Issues
to
Consider


Liability
Frameworks

For
AI
Agents,
liability
is
usually
straightforward

often
tied
to
the
deploying
company.
However,
with
Agentic
AI,
where
systems
operate
autonomously
and
evolve
over
time,
liability
can
become
fragmented.
Key
considerations
include
drafting
clear
indemnification
clauses
in
vendor
agreements,
requiring
ongoing
audits
of
AI
system
performance,
and
addressing
cross-jurisdictional
liability
when
systems
operate
internationally.


Regulatory
Compliance

Emerging
regulations,
like
the
EU
AI
Act,
differentiate
between
AI’s
risk
levels.
For
high-risk
applications
like
Agentic
AI
in
health
care
or
transportation,
compliance
requirements
may
include
transparent
documentation
of
the
AI’s
decision-making
processes,
incorporation
of
human
oversight
mechanisms,
and
regular
assessments
for
bias
and
safety.


Ethical
Considerations

Agentic
AI
introduces
significant
ethical
questions,
such
as:
how
to
address
biases
that
AI
systems
might
develop
autonomously,
and
whether
AI
decisions
can
be
explained
in
a
way
that
satisfies
stakeholders
and
regulators.


Data
Privacy

Both
AI
types
rely
heavily
on
data,
raising
risks
under
privacy
frameworks
like
GDPR
or
CCPA.
Ensure
that
consent
is
obtained
for
data
collection,
that
systems
have
robust
cybersecurity
measures,
and
that
AI
Agents
handling
sensitive
data
comply
with
sector-specific
privacy
laws
(e.g.,
HIPAA
for
healthcare).


IP
Protection

AI
systems
can
create
original
outputs,
from
artwork
to
software
code.
Legal
teams
must
evaluate
whether
these
outputs
qualify
for
intellectual
property
protection
and
address
potential
copyright
infringement
risks.


Actionable
Steps
For
In-House
Counsel

To
effectively
manage
AI’s
legal
and
ethical
challenges,
consider
the
following:


  • Develop
    Tailored
    Contracts.

    Address
    unique
    risks
    for
    each
    AI
    type,
    specifying
    liability,
    audit
    rights,
    and
    compliance
    obligations.

  • Implement
    Governance
    Policies.

    Establish
    internal
    frameworks
    for
    the
    ethical
    use
    of
    AI,
    focusing
    on
    transparency,
    accountability,
    and
    risk
    mitigation.

  • Engage
    Stakeholders.

    Involve
    cross-functional
    teams

    including
    IT,
    risk
    management,
    and
    compliance

    to
    ensure
    holistic
    oversight
    of
    AI
    systems.

  • Monitor
    Evolving
    Laws.

    Stay
    ahead
    of
    AI-specific
    legislation,
    particularly
    in
    high-risk
    sectors
    like
    transportation,
    healthcare,
    and
    finance.


Looking
Ahead

AI
Agents
and
Agentic
AI
are
rapidly
advancing,
with
both
offering
tremendous
potential

and
unique
legal
challenges

for
businesses.
As
the
distinction
between
these
systems
blurs,
legal
teams
must
remain
agile,
ensuring
that
their
organizations
leverage
AI
responsibly
while
protecting
against
liabilities.

For
deeper
insights
into
how
in-house
lawyers
can
navigate
these
complex
issues
while
driving
innovation,
my
book,
Product
Counsel:
Advise,
Innovate,
and
Inspire
,”
offers
practical
guidance.
From
crafting
proactive
legal
strategies
to
fostering
cross-functional
collaboration,
it
equips
counsel
to
address
the
challenges
of
AI
and
other
cutting-edge
technologies
with
confidence
and
creativity.

How
is
your
company
adapting
to
the
rise
of
AI?
Have
you
encountered
unexpected
legal
challenges?

Let’s
discuss

share
your
experiences
and
insights.




Olga MackOlga
V.
Mack



is
a
Fellow
at
CodeX,
The
Stanford
Center
for
Legal
Informatics,
and
a
Generative
AI
Editor
at
law.MIT.
Olga
embraces
legal
innovation
and
had
dedicated
her
career
to
improving
and
shaping
the
future
of
law.
She
is
convinced
that
the
legal
profession
will
emerge
even
stronger,
more
resilient,
and
more
inclusive
than
before
by
embracing
technology.
Olga
is
also
an
award-winning
general
counsel,
operations
professional,
startup
advisor,
public
speaker,
adjunct
professor,
and
entrepreneur.
She
authored 
Get
on
Board:
Earning
Your
Ticket
to
a
Corporate
Board
Seat
Fundamentals
of
Smart
Contract
Security
,
and  
Blockchain
Value:
Transforming
Business
Models,
Society,
and
Communities
. She
is
working
on
three
books:



Visual
IQ
for
Lawyers
(ABA
2024), The
Rise
of
Product
Lawyers:
An
Analytical
Framework
to
Systematically
Advise
Your
Clients
Throughout
the
Product
Lifecycle
(Globe
Law
and
Business
2024),
and
Legal
Operations
in
the
Age
of
AI
and
Data
(Globe
Law
and
Business
2024).
You
can
follow
Olga
on




LinkedIn



and
Twitter
@olgavmack.