Steam recently introduced a bunch of AI disclosure requirements for games listed on its store. We’re going to unpack these in a little more detail and help you understand what’s expected of you.

Why do AI disclosures matters?

We shouldn’t treat AI disclosure as just a regulatory formality.  AI disclosure requirements serve a vital purpose in the gaming ecosystem. You need to inform your players of aspects shaping their gaming experiences. Transparency builds trust between developers and players, enhancing the overall relationship and potentially increasing user satisfaction.

Unpacking the AI disclosure requirements

The requirements require developers to disclose the presence and functionality of these AI systems in their games. This disclosure encompasses any AI-driven features such as adaptive difficulty, procedural content generation, and in-game decision-making processes.

Navigating the disclosure process

Developers should diligently approach the disclosure process to comply with Steam’s guidelines. The guidelines separate AI usage into two broad categories:

  • pre-generated content – any content developers create during the games early stage development; and
  • live-generated content – any content created with the help of AI while the game is in use.

These disclosures will help Steam determine whether a particular game breaches its distribution agreement.  Steam will also include your disclosures in the description of the game to ensure that players understand how you use AI in your games.

What if we don’t comply?

If you don’t follow the AI disclosure requirements, your game will either:

  • not be listed on the store;
  • removed from the store if listed previously; and,
  • if there is any illegal or infringing content, there may be further legal consequences.

We also don’t know how courts will deal with actions relating to generative AI. These requirements will go a long way in helping game developers be transparent.

Actions you can take next

We can help you:

  • determine how the AI disclosure requirements impact your organisation by asking us to perform an AI risk assessment.
  • review your AI disclosures to ensure they align with the Steam disclosure requirements.
  • stay updated with the latest AI law news by subscribing to our newsletter.
  • discover more about AI by reading our AI law page.