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If your game uses generative AI, disclose the specific player-facing content and distinguish material created during development from content generated during play. On Steam, developers report both categories in the Content Survey; for releases involving the EU, Article 50 of the AI Act adds transparency duties for certain kinds of synthetic content, not a blanket label for every creative game asset.
What AI use should you disclose?
Start by listing each AI use that could affect what players see, hear, read, or interact with. Record what the AI produces, where it appears, and when it is created. A generated character portrait bundled with the game is different from dialogue generated in response to a player during a session.
Steam’s Content Survey focuses on AI used to create content that “ships with your game, and is consumed by players.” Steam names artwork, sound, narrative, and localization as examples. Its categories are based on when the content is generated:
- Pre-generated: content made with AI tools during development, included in the shipped game, and consumed by players.
- Live-generated: content made with AI tools while the game is running.
Do not assume that an AI tool used somewhere in production automatically means the same disclosure as player-facing generated content. Follow the current submission form for the storefront and describe the actual use rather than making a broad, vague claim.
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How to disclose AI-generated content on Steam
Use Steamworks’ current Content Survey and answer its AI questions according to what the game actually contains. Valve says much of the disclosure is shown on the game’s store page, so the information should help customers understand what they may encounter.
- Identify each AI-produced asset or feature. Name the content type—such as artwork, sound, narrative, or localization—and where it appears in the game.
- Classify when it is generated. Mark content created during development separately from content generated while the game is running.
- Describe live-generation safeguards accurately. Steam asks developers using live-generated content to explain the guardrails intended to prevent illegal output. State the controls that are implemented and what they do; do not imply protections exist if they do not.
- Check the current form and store-page result. Steam’s rules and forms can change. Confirm that the submitted answers match the build and the information customers will see.
Steam also says AI-generated content is reviewed before release under the same standards as non-AI content. Its Distribution Agreement requires developers not to include illegal or infringing content and to keep the game consistent with its marketing materials. Disclosure does not replace those obligations.
What does EU AI Act Article 50 require?
For releases involving the European Union, avoid treating Article 50 as a rule to label every AI-assisted creative asset for players. It distinguishes duties by actor and content category. The European Commission says the relevant transparency obligations apply from 2 August 2026. The specific result depends on who is acting, what the system generates, and how the content is used; consult the regulation and seek qualified legal advice for a concrete release decision.
Providers: machine-readable marking of synthetic output
Providers of AI 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 the qualifications in Article 50. The regulation identifies exceptions for assistive standard editing and changes that do not substantially alter input data or its semantics. This is a provider duty; it is not the same as a game developer’s storefront disclosure.
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Deployers: disclosure for specified 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. If such content forms part of an evidently artistic, creative, satirical, fictional, or analogous work, the disclosure is limited to acknowledging the existence of generated or manipulated content in an appropriate way that does not hamper display or enjoyment.
Deployers: a narrow rule for public-interest text
Article 50 also covers AI-generated or manipulated text published to inform the public on matters of public interest. The duty has an exception where the text has undergone human review or editorial control and a natural or legal person holds editorial responsibility. Fictional game dialogue should not be casually treated as public-interest publication merely because it is text.
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Timing and presentation
Where Article 50 requires information under paragraphs 1–4, it must be provided clearly and distinguishably no later than the first interaction or exposure, subject to applicable accessibility requirements. The European Commission’s Code of Practice supports compliance with marking and labeling obligations, but the Code is voluntary; the legal duties in Article 50 are not. The Commission also provides optional icons for deployers.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.A practical disclosure template
Use wording that matches the verified implementation and the platform’s form. For example:
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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].
Replace the brackets with concrete details. If an AI-generated feature has more than one use, describe each separately rather than implying that all content is produced the same way. Do not claim a safeguard, review process, or limitation unless it is actually in place.
Review each AI use before release
A simple inventory helps prevent omissions when one game uses AI in several ways. For every use, record:
- Timing: created during development or generated while the game runs.
- Player exposure: whether it ships in the game or appears in the store page or promotional material, and whether players see, hear, read, or interact with it.
- Content type: for example, artwork, sound, narrative, or localization.
- Possible legal category: whether the use involves direct interaction with an AI system, a deepfake, or public-interest text covered by Article 50.
- Controls: for live output, the safeguards actually implemented and what they are intended to prevent.
Steam’s survey is Steam-specific, and EU Article 50 applies to specified cases. Neither establishes the rules for every storefront, country, contract, or age-rating body. Check each platform’s current submission requirements and the law that applies to the release.
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