Disclose every AI-generated element that players will receive, use the destination store’s own submission workflow, and keep a separate record of human authorship and licensing. On Steam, that means completing the Content Survey before the store page and build go to review, identifying whether content is pre-generated or created during play, and describing real safeguards for live generation. A disclosure is not a copyright license: you still need rights to source material and outputs, and U.S. copyright protection generally extends only to sufficiently creative human contributions. The workflow below covers Steam first, then itch.io, Microsoft Store, Google Play and Apple’s narrower rules, followed by practical U.S. registration guidance.
What counts as AI-generated content in a game?
Start with what a player encounters, not merely which tools your team opened. Separate final art, music, sound effects, voices, written dialogue, localization and other material created or materially assisted by an AI system from content generated in response to a player during gameplay. Also record AI use in marketing assets when a store’s rule reaches promotional material. Ordinary efficiency gains, such as using an AI tool to help search code or organize notes, are not automatically the same as shipping AI-created expressive content.
Inventory pre-generated assets
List every AI-assisted or AI-generated item that remains in the release: background illustrations, character portraits, textures, music, voice lines, dialogue, item descriptions, subtitles and translated text are typical examples. Record the file or scene location, the generating service or tool, the person who selected or edited it, the source material used, and the rights terms that applied at creation. If an artist substantially redraws an output, describe both the generated starting point and the human changes rather than collapsing them into a single label.
Identify live generation
Runtime generation is a separate risk category. Note exactly what the game creates from a player prompt or other input, where it appears, whether it can be saved or shared, and what moderation, filtering, reporting and blocking controls operate before or after display. A game with fixed AI-made portraits has a different disclosure from one that writes new dialogue for every player.
Do not confuse procedural systems with generative AI
Traditional NPC pathfinding and procedural level generation are not automatically generative-AI content. itch.io’s creator guidance asks developers to distinguish those systems from material produced by generative models, although each store can define its own scope. When a system combines both methods, describe the model-generated part and the conventional algorithm separately.
How do I complete Steam’s AI disclosure?
Steam’s current Content Survey documentation requires accurate answers before you submit the store page and build for review. Steam compares the survey with the build and page, so write from the shipped player experience and keep the wording synchronized.
- Finish the asset inventory first. Mark each item as pre-generated and shipped with the build, or generated live from user input. Include sound, text, dialogue, images and other player-facing material, not just the most visible artwork.
- Open the Content Survey before review submission. Complete the AI section as part of the normal Steamworks submission sequence. The survey is Steam’s disclosure channel; it is not a substitute for checking licenses or copyright.
- Describe pre-generated material concretely. State what the model produced, where it appears, and what human selection, editing or arrangement was performed. Do not imply that a tool was used only for brainstorming if generated material remains in the release.
- Describe live generation and its safeguards. Explain the input path, the output shown to players and the actual controls intended to prevent illegal output. A generic promise that content is “moderated” is weaker than naming the implemented filter, review queue, blocked categories, reporting route or removal process.
- Check the store page and build against the answers. Screenshots, trailers, descriptions and tags should not suggest a different AI implementation. Steam’s survey is about material consumed by players; its documentation says, “Efficiency gains through the use of these tools is not the focus of this section.” That sentence should not be expanded into a universal exemption for every platform or every type of AI-assisted work.
- Ask Support before making a consequential change. Steam says some survey answers cannot be edited after the build and store page are approved without first contacting Support. If an update adds runtime generation or changes the type of player-facing output, resolve the survey status before publishing the update.
Steam also states that it does not currently ship Adult Only Sexual Content games using live-generated AI sexual content. Treat that as a current Steam rule, not as a general statement about other stores or jurisdictions.
What should my Steam disclosure say?
Use plain language that a reviewer can compare with the actual game. The following is illustrative wording, not Valve-approved form text:
We used generative AI to produce some background illustrations during development. Our artists selected and edited the illustrations used in the released game. The game does not generate illustrations during play.
Replace every part of that example with your actual implementation. If the game generates dialogue at runtime, identify the feature, the player inputs that trigger it, the surfaces where the response appears and the safeguards that are really deployed. If AI-created material appears only in a trailer or screenshot, verify whether the destination store treats that promotional asset separately and disclose it where required.
How do other storefronts handle AI disclosure?
Store rules differ in trigger, location and scope. A missing published rule is not blanket permission to omit disclosure; use the current submission form and policy for the store and territory in which you distribute.
| Store | Published trigger or scope | Where to disclose | Additional requirement or limit |
|---|---|---|---|
| Steam | Pre-generated player-consumed content and live-generated content | Steamworks Content Survey before store-page and build review | Live generation requires a description of safeguards against illegal output; answers are checked against the build and page. Steam documentation |
| itch.io | Generative-AI material in Graphics, Sound, Text & Dialog, or Code categories | Project edit page’s “Generative AI disclosure” field; selecting yes creates AI-related tags | The announcement makes the field required for asset creators and asks projects to tag accurately; it distinguishes generative AI from traditional pathfinding and procedural generation. itch.io announcement |
| Microsoft Store, including Xbox-branded stores | Version 7.20, effective October 22, 2026, covers live content generated in response to user inputs | Product metadata and Partner Center | Products must comply with Store Policies and provide a way to report inappropriate output. The cited provision addresses live generation, not a universal label for fixed assets. Store Policies |
| Google Play | Applicable AI-generated or edited images and videos introduced through store-listing and promotional creation flows | Individual self-declaration in the relevant Play Console flow | Declared promotional assets receive AI labels where used. This guidance does not establish a comprehensive declaration for every AI system inside a game. Play Console guidance |
| Apple App Store | Guideline 1.2 includes AI content-creation apps among services with user-generated content risks | App Review submission and the app’s user-safety implementation | Filtering, abuse reporting and response, user blocking and contact information are required for the covered services. This is not a general badge for pre-made game art. App Review Guidelines |
Before each submission, reread the live policy and form. Platform wording and fields can change independently, and a rule written for promotional media or live user-generated output should not be stretched to cover every possible development use.
Does an AI disclosure give me permission to ship the content?
No. Disclosure tells a platform how AI appears in the product; it does not grant a license, cure infringement or guarantee that a store will accept the game. Steam separately requires compliance with its content rules and non-infringement and marketing-consistency promises.
Check contractual permission
Read the terms for the model, generator, voice service, stock library or other supplier used for each asset. Determine whether commercial use is allowed, whether attribution is required, whether outputs can be sublicensed to a store and whether the provider reserves rights that conflict with your release. Keep the version and date of the terms with the asset record.
Check source material and recognizable expression
A tool’s commercial-use clause does not decide whether an output reproduces a protected character, logo, photograph, voice or other third-party expression. Review reference images, uploaded training material, prompts that request a living artist’s style and any recognizable elements independently. Steam’s survey does not adjudicate those facts, and a store label cannot make them lawful.
Check the human contribution
Record who selected, arranged, edited, redrew, recorded, wrote or otherwise shaped the final work. Those facts matter to copyright analysis and to proving what your team actually created. Prompt logs or screenshots can document process, but they do not by themselves prove ownership or clearance.
Can I copyright a game that uses AI?
Under the U.S. Copyright Office’s January 2025 analysis, AI assistance does not automatically disqualify a larger human-authored work. Protection turns on the human expression in the specific game: sufficiently creative selection or arrangement of material, or original human modifications, may be protected, while machine-determined output is not automatically covered just because a person entered a prompt.
The Office’s report explains that prompts alone generally do not provide enough control over the output’s expressive details with generally available systems. Conversely, an AI-assisted game can contain protectable code, writing, level arrangement, character design decisions, editing and other human-authored elements. The resulting copyright claim may cover those qualifying contributions without covering the underlying AI output itself. As Register of Copyrights Shira Perlmutter put it, “Where that creativity is expressed through the use of AI systems, it continues to enjoy protection.” See the Copyright Office report for the fact-specific analysis.
The Office’s 2025 AI work drew more than 10,000 responsive comments, but that number is background about public input, not a count of AI games, registrations or infringement cases. It does not establish how often developers use AI or whether disclosure changes sales. The Office’s announcement provides that context.
How do I register a mixed human-and-AI game in the United States?
Registration is a separate disclosure process from a store survey. If you apply to register a mixed work, follow the Copyright Office’s AI registration guidance and describe the human-authored portion accurately.
- Use the Standard Application. Identify the game and the authors who contributed protectable human expression.
- Describe human authorship in “Author Created.” State the original code, text, art, music, editing, selection, arrangement or other human contribution being claimed.
- Exclude more-than-de-minimis AI material. Use “Limitation of the Claim” and “Material Excluded” to identify AI-generated portions that are not being claimed as human authorship.
- State uncertainty rather than guessing. If you cannot determine the extent of AI material, the Office says you may state generally that the work contains AI-generated material; it can follow up.
- Correct an omission. For a pending application that omitted AI material, contact the Office’s Public Information Office. For an issued registration, the guidance calls for a supplementary registration.
Nothing in this procedure requires every developer to register a game before publishing it. It governs what you claim if you choose U.S. registration.
Can model training data make my game infringing?
There is no universal yes-or-no answer. The Copyright Office separates copyrightability of outputs from its May 2025 pre-publication analysis of AI training, and neither report certifies a particular game or asset as infringement-free. A shipped asset still requires a fact-specific review of its source, the output, the tool’s terms and the law that applies to the relevant country.
Use the Office’s AI materials as explanations of the legal questions, not as a clearance certificate. The Office’s central AI resources are collected at copyright.gov/ai. A disputed character, song, voice or image may warrant advice from a qualified lawyer who can examine the actual files, licenses and distribution plan.
What records should I keep before release?
A practical file for each asset makes store answers and later rights questions easier. This is recommended recordkeeping, not a mandated Steam form.
- Asset identifier, file path, scene or marketing placement and release version.
- Whether the asset is AI-assisted, AI-generated, human-created or a combination.
- Whether it ships pre-generated or is produced during play, including the player input that triggers it.
- Tool or supplier name, account or plan, relevant terms and the date those terms were checked.
- Source images, audio, text or datasets supplied to the tool and the permissions for each.
- Human contributors and a concise description of their edits, selection, arrangement or original additions.
- Moderation, filtering, reporting, blocking and removal controls for live output.
- The exact store disclosure, page copy, screenshots and build version submitted together.
- Copies of support correspondence when a store changes or locks a survey answer.
Do not claim that a prompt log, screenshot or vendor statement alone proves legal clearance. They are evidence of process, not a substitute for checking rights in the actual material.
What should I do when a policy or asset changes?
Recheck the Steam Content Survey, each destination store’s submission form and the U.S. Copyright Office guidance immediately before a policy-dependent submission or registration. A patch that adds a live model, replaces a voice, introduces new promotional images or changes moderation can alter the relevant disclosure even when the game’s title and genre stay the same. Keep the store page, survey answers and build description synchronized, and contact the platform before approval if its workflow prevents you from editing an answer.
Frequently Asked Questions
Do I need to disclose AI that was used only for brainstorming?
If no generated text, image, audio or other expressive material remains in the player-facing game or promotion, Steam’s published survey focus generally does not treat ordinary behind-the-scenes efficiency as the target. Keep an internal note of the use anyway, and check the destination store’s current form because another platform may define its scope differently.
What happens if I add AI-generated dialogue in a later patch?
Treat the patch as a new disclosure decision, not as covered by the original approval. Update the store description and survey information where the workflow permits, and contact Steam Support before release if an approved answer is locked.
Is procedural generation the same as generative AI for store tags?
Not necessarily. itch.io’s guidance distinguishes traditional NPC pathfinding and procedural level generation from generative-AI material, but stores can use different definitions. Describe the model-generated component separately whenever both systems are present.
Does registering my game protect every AI-made asset inside it?
No. A U.S. registration for a mixed work should identify human authorship and exclude more-than-de-minimis AI-generated material. Protection can cover qualifying human edits, selection or arrangement without automatically covering the model-determined output.
When should I get individual legal advice?
Consider it when an asset resembles a protected character, person’s voice or artwork, when source permissions are unclear, or when a commercial release depends on a disputed tool license. A lawyer can evaluate the actual files and contracts; a store disclosure cannot resolve those questions.