Steam AI Disclosure Policy Updated: Efficiency Tools Now Exempt
- Aisha Washington
- Jan 19
- 5 min read

Valve has officially refined the Steam AI disclosure policy, resolving a major ambiguity that has plagued developers for the past year. The platform no longer requires developers to flag games that use Artificial Intelligence for "efficiency" tasks behind the scenes. This move draws a sharp line between tools used to build a game—like coding assistants—and AI-generated assets that players actually see or hear.
For studios and solo developers previously confused about whether using GitHub Copilot or Photoshop’s Generative Fill required a special disclaimer, the new rules provide immediate clarity.
Developer Experiences Under the Steam AI Disclosure Policy

Before dissecting the legal text, it is useful to look at how developers are actually utilizing these tools in production. The previous iteration of the Steam AI disclosure policy created friction because it didn't account for the nuance of modern workflows.
According to technical discussions surrounding the update, seasoned developers aren't just using AI to generate final assets; they use it as an interactive documentation tool. The consensus among professionals is that Large Language Models (LLMs) function best as "rubber ducks"—a sounding board for logic problems—rather than creators of final code.
Using AI for "Rubber Ducking" and Search
A common workflow involves using models like Gemini or Claude to parse poorly written API documentation. Instead of scouring StackOverflow, which some users note has seen a dip in engagement, developers paste error logs or documentation into an LLM to get a "translation" of the problem. Under the old interpretation of the Steam AI disclosure policy, this internal problem-solving step might have arguably triggered a disclosure requirement. The new update clarifies that this is exempt.
The "Vibe Coding" Risk
Not all developer experiences are positive. The community distinguishes heavily between "efficiency" and what is now being called "vibe coding." This refers to inexperienced creators who rely entirely on AI to write code they don't understand.
While the updated Steam AI disclosure policy permits the use of AI for coding without a public label, community feedback highlights a risk: code generated by AI is prone to hallucinations. Users report instances where AI invents forum posts or cites non-existent documentation. The exemption for efficiency tools is a relief for competent engineers, but it doesn't change the technical reality that unverified AI code can break game logic. The policy change simply means Valve won't act as the police for bad code, only for illegal or infringing content.
How the New Steam AI Disclosure Policy Defines Content

The core of the update is a classification system that separates the development pipeline from the player experience. Valve now categorizes AI use into two distinct buckets: Pre-generated content and Live-generated content.
Pre-generated Content vs. Efficiency Tools
This is where the Steam AI disclosure policy has shifted most significantly.
Efficiency Tools (Exempt): If you use AI to write code, brainstorm concepts, or streamline workflows, but the AI output isn't directly included in the game files, you do not need to disclose it.
Pre-generated Content (Disclosed): If the AI generates art, music, or dialogue that ships with the game, it must be disclosed.
This solves the "Photoshop problem." Previously, if a concept artist used generic generative fill to extend a background during the drafting phase, it was unclear if that triggered the label. Now, if that draft doesn't end up on the screen of the final player, it is considered an efficiency tool.
Live-Generated Content and Guardrails
For games that use AI in real-time—such as an NPC that generates unique dialogue based on player voice input—the Steam AI disclosure policy remains strict. Developers must disclose this function.
More importantly, developers are required to detail the "guardrails" they have in place. Since the developer cannot verify the content before the game ships (because it is generated live), they must prove to Valve that the AI will not generate illegal or prohibited content.
To support this, Valve has integrated a new feature in the Steam Overlay. Players can now flag specific content within a game as being "illegal AI generation." This shifts some of the moderation burden to the community, giving players a direct line to report when a live-generated system goes off the rails.
Community Analysis of the Steam AI Disclosure Policy

The reception to the updated Steam AI disclosure policy reflects a divide between platform holders and industry figures.
Epic Games CEO Tim Sweeney has argued that disclosure labels for AI are temporary measures that will eventually become obsolete as AI permeates all software production. His view suggests that eventually, "made with AI" will be as redundant as saying "made with computers."
However, industry observers and Valve seem to disagree with that inevitability. By refining the Steam AI disclosure policy, Valve acknowledges that players currently care about the distinction. There is a specific consumer demand to know if the anime artwork in a visual novel was drawn by a human or generated by a model.
Preserving Consumer Choice
The policy essentially protects consumer choice. Players who wish to avoid AI-generated assets can still use the disclosure warning to inform their purchasing decisions. Meanwhile, players who don't care how the code was written (efficiency tools) aren't bombarded with meaningless warnings on every store page.
Critically, the update aligns with the reality of software development. Codebases can reach millions of lines. If a developer uses AI to generate unit tests or boilerplate code for a fraction of that, labeling the entire project as "AI-generated" dilutes the meaning of the label. The updated Steam AI disclosure policy restores value to the label by reserving it for creative assets.
The Future of AI in Game Development

The distinction made in the Steam AI disclosure policy sets a precedent for other digital storefronts. It validates the use of AI as a background instrument while maintaining transparency for the front-facing product.
For developers, the actionable takeaway is clear:
Review your pipeline: Identify where AI is used.
Classify usage: Is it a tool (Copilot/IDE features) or an asset generator (Midjourney/Suno)?
Check Guardrails: If your game uses live generation, ensure you have hard-coded filters for safety, as players now have a dedicated reporting button.
Valve’s approach suggests they are not looking to ban AI, but to catalog it correctly. As tools like Rosebud AI and other "no-code" builders evolve, the definition of a "game developer" may shift, but the definition of what constitutes a "product" on Steam is now clearer.
FAQ: Steam AI Disclosure Policy
Do I need to disclose using GitHub Copilot under the new Steam AI disclosure policy?
No. Tools used to write code or assist in development are classified as "efficiency tools" and are exempt from disclosure, provided the AI-generated code doesn't include illegal content.
What counts as "Live-Generated" content?
Any content created by an AI system while the game is running, such as dynamic NPC conversations or real-time texture generation. This requires disclosure and safety guardrails.
Does the Steam AI disclosure policy apply to marketing materials?
Yes. If you use AI to generate assets specifically for your store page, trailers, or screenshots, this falls under the disclosure rules for pre-generated content.
How does Valve enforce the policy for live AI content?
Valve has added a reporting tool in the Steam Overlay allowing players to flag illegal AI-generated content immediately. Developers are responsible for ensuring their guardrails prevent this content from appearing.
What if I use AI for concept art that isn't in the final game?
You do not need to disclose this. Internal concept art that is not distributed to players counts as part of the efficiency and development process.