Separate AI content made during development from content generated while the game runs, then disclose each use according to the relevant storefront rules and laws for your release. On Steam, the Content Survey asks about AI-created content that ships with the game and is consumed by players, and asks developers using live-generated content to describe safeguards against illegal output. EU rules are narrower than a blanket label for every creative asset: Article 50 applies to specified synthetic media and disclosure cases, with duties depending on the actor and content.
What AI use should you disclose?
Make an inventory of each use of generative AI and answer four questions: when the content is made, whether players encounter it, what kind of content it is, and whether it is generated live. These distinctions matter because a finished background illustration included in a game is different from dialogue generated in response to a player during play.
- Timing: Was the content created during development, or does the game generate it while running?
- Player exposure: Do players see, hear, read, or interact with the result in the shipped game or its store materials?
- Content type: Is it artwork, sound, narrative, localization, or something else?
- Controls: If output is generated live, what safeguards are actually in place?
Do not describe a use more broadly than it is. If a tool assisted with internal planning but its output does not appear in player-facing content, distinguish that from AI-generated material players encounter.
How to disclose AI-generated content on Steam
Steamworks’ Content Survey focuses on AI used to create content that “ships with your game, and is consumed by players.” It gives artwork, sound, narrative, and localization as examples. Steam distinguishes pre-generated content from content generated while the game is running. Steamworks Content Survey
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Pre-generated content
Pre-generated content is made with AI tools during development, then included in the game for players to consume. Identify what the tool produced and where it appears—for example, character portraits, music, dialogue, or localized text. Steam says AI-generated content is reviewed before release under the same standards as non-AI content.
Live-generated content
Live-generated content is produced by AI tools while the game is running. Steam asks developers to describe guardrails intended to ensure the system does not generate illegal content. State the safeguards that are implemented and how they apply; do not imply protections exist if they have not been built or verified. Valve also says developers promise under the Steam Distribution Agreement not to include illegal or infringing content and to keep the game consistent with its marketing materials. Valve’s announcement on AI-generated content
A practical Steam disclosure
Use the current Content Survey and make the description specific enough for players to understand what they may encounter. Adapt this wording only to verified facts:
Generative AI was used to create [specific content type] for [specific location or feature]. This content [ships with the game / is generated during play]. For live-generated content, [brief, factual explanation of safeguards].
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Steam says much of the disclosure appears on the game’s store page, so ensure the description matches the actual shipped experience.
What the EU AI Act requires—and what it does not
Article 50 of the EU AI Act is not a general requirement to label every creative game asset for players. It sets distinct transparency duties for providers of certain AI systems and deployers in specified situations. The European Commission says these obligations apply from 2 August 2026. European Commission guidance on AI-generated content · Regulation (EU) 2024/1689, Article 50
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Provider duties for generative systems
Providers of systems that generate synthetic audio, image, video, or text must ensure outputs are marked in a machine-readable format and detectable as artificially generated or manipulated, subject to qualifications in the Act. It includes exceptions for assistive standard editing and changes that do not substantially alter input data or its semantics. These provider duties are distinct from a game developer’s player-facing disclosure obligations.
Deployer disclosure for deepfakes
Deployers must disclose when they use an AI system to generate or manipulate image, audio, or video that constitutes a deepfake—content that would falsely appear authentic or truthful. When that content is part of an evidently artistic, creative, satirical, fictional, or analogous work, disclosure is limited to appropriately identifying the existence of generated or manipulated content in a way that does not hamper display or enjoyment.
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Deployer disclosure for certain public-interest text
A separate duty covers AI-generated or manipulated text published to inform the public on matters of public interest. The Act provides an exception where the text has undergone human review or editorial control and a person holds editorial responsibility. Fictional dialogue in a game should not automatically be treated as publication of public-interest information.
Timing and presentation
Information required under Article 50’s relevant paragraphs must be clear and distinguishable and provided no later than the first interaction with or exposure to the content, subject to applicable accessibility requirements. The Commission’s Code of Practice supports compliance with marking and labeling duties but is voluntary; the Act’s legal obligations are not. The Commission reported that about 190 organizations had signed the Code by the end of July 2026. European Commission Code of Practice on AI-generated content
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to check a game with several AI uses
Assess each use separately rather than writing one vague statement about “AI.” The same game may contain fixed AI-assisted artwork, live-generated dialogue, and a separate feature involving synthetic audio; each can raise a different platform or legal question.
| Check | Question |
|---|---|
| Timing | Was the result made during development, or generated while the game runs? |
| Player exposure | Where does it appear, and can players see, hear, read, or interact with it? |
| Content type | Is it artwork, sound, narrative, localization, or another type of content? |
| Regulatory category | Does the feature involve direct interaction with an AI system, a deepfake, or public-interest text covered by Article 50? |
| Controls | For live generation, which safeguards are implemented, and what do they do? |
Check rules for every storefront and release region
Steam’s survey is a platform submission rule, not a substitute for legal analysis or another storefront’s requirements. Article 50 depends on the roles involved and the content and use in question. Confirm the current submission instructions for each platform and assess applicable law in each release jurisdiction; for a concrete compliance decision, consult qualified local counsel.
