Does a dragon need material components, specifically body bits, for a Simulacrum spell?

Question

Please consider an ancient Green dragon with the variant ability to cast spells. She would like to cast Simulacrum.

Monster Manual Page 86 / Variant:

VARIANT: DRAGONS AS INNATE SPELLCASTERS: Dragons are innately magical creatures that can master a few spells as they age, using this variant.

A young or older dragon can innately cast a number of spells equal to its Charisma modifier. Each spell can be cast once per day, requiring no material components, and the spell's level can be no higher than one-third the dragon's challenge rating (rounded down) . The dragon's bonus to hit with spell attacks is equal to its proficiency bonus+ its Charisma bonus. The dragon's spell save DC equals 8 +its proficiency bonus + its Charisma modifier.

As noted she is CR: 22 with 19 charisma - giving her four spells to cast once per day / 7th level spell maximum. No problems thus far. She is concerned about the material components for this Simulacrum spell...

Components: V, S, M - Snow or ice in quantities sufficient to made a life-size copy of the duplicated creature; some hair, fingernail clippings, or other piece of that creature’s body placed inside the snow or ice; and powdered ruby worth 1,500 gp, sprinkled over the duplicate and consumed by the spell.

... but she realizes (thanks to 'variant', above) that she casts all her spells 'requiring no material components'. This is her lucky eon! She will have to choose fun spells like Awaken and Reincarnate so as to build up an immortal army of her favourite treasure-people-beasts! But she digresses.

This zero materials required means she need not worry over the expensive powdered ruby - nor even the snow for that matter. But what of the hair, clippings (or 'other body parts')? If ANY components are allowed, can she cast any humanoid or beast that has ever lived in history? She could theoretically magic-pretend that she procured these left over parts before that person or beast died. Can she even create duplicates of imaginary people with this casting? Is there a way that anyone could defend themselves from being copied? Some may have Mind Blank or Protection vs. Nasty &/or Goodness or reside on another plane of existence. How does one defend themselves from this 3D printer of doppelgängers?

The reason this is relevant: If she has access to any body parts without impunity, she could conjure up any high cleric or archmage in existence at no cost. The next day she could conjure up another, for free. This is bizarrely powerful. To be honest, even the ability to conjure up the same archmage from a specific ball of hair, gaining Wish on a daily basis (without limits) is a bit extreme.

Long story short: A dragon casts spells without need of ANY components. What kinds of Simulacrum persons &/or creatures can they make?

Answer 1

They need no material components, ergo they need no material components

Like it says in variant creature panel, they don't need any material components. Like it says in the simulacrum spell description, the bit of creature is a material component.

Simulacrum only duplicates a creature you are touching

Simulacrum has range: touch, casting time: 12 hours, and duplicates a target within range for the full casting of the spell. This means most simulacrum casters duplicate, primarily, themselves. They certainly aren't duplicating any long-dead beings without first ressurecting those beings and convincing them to hold relatively still while being touched for 12 hours.

This is too powerful!

Of course, an Ancient Dragon with arbitrarily many perfectly loyal copies of archmages is pretty powerful, perhaps more powerful than its mechanically assigned CR would indicate. That's why there's a GM and the GM decides what monsters exist and are encountered and how they work. What is surprising here is that the rules mostly work as-written-- they usually break down as soon as you look too closely.

How to avoid being cloned

Don't continuously touch someone for 12 hours straight. If you limit your constant touching time to 11 hours you will be okay. Change your clothes twice daily if you are really paranoid.

Answer 2

The dragon doesn't need a part of the target

While some spells require components that are not material components, the piece of the target's body is a material component needed to cast Simulacrum:

Components

V, S, M*

*- (snow or ice in quantities sufficient to made a life-size copy of the duplicated creature; some hair, fingernail clippings, or other piece of that creature's body placed inside the snow or ice; and powdered ruby worth 1,500 gp, sprinkled over the duplicate and consumed by the spell)

As you noted above, the dragon does not need material components:

Each spell can be cast once per day, requiring no material components

So you do not need any part of the target creature.

The target must still be in range

Simulacrum states:

You shape an illusory duplicate of one beast or humanoid that is within range for the entire casting time of the spell.

This limitation remains even if you don't need any material components. The target must remain within touch range for the full 12 hours. That means no imaginary creatures, and the spell can easily be countered by moving away.

How would you fight an army of Simulacrums?

Depends how long the dragon has to make an army, but there's no easy answer for that one. Fighting a dragon alone would be a Tier 4 adventure already. Perhaps it would be easier to find a non-combat solution, or just accept life under your new dragon overlord.