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Steam Generative AI Policy
Effective January 2026 · Applies to all games using AI-generated player-facing content
What the policy requires
Valve's policy mandates that any game with AI-generated content must clearly disclose it on the Steamworks store page before launch. The policy draws a hard distinction between two categories:
| Category | Definition | Example |
|---|---|---|
| Pre-Generated | AI was used to create assets during development; the output is fixed in the shipped game | Character portraits generated with Midjourney; background music composed with Suno |
| Live-Generated | AI generates content in real time during gameplay, specific to each session or player | Procedural dialogue via GPT; dynamic NPC faces |
Failure to disclose — or incorrect categorisation — results in Valve rejecting your store page submission or delisting your game after launch.
How OriginGuard satisfies Steam requirements
| Obligation | OriginGuard Output | Status |
|---|---|---|
| Disclose AI-generated player-facing content | steam_disclosure.disclosure_statement — copy-paste ready text |
✓ Covered |
| Distinguish Pre-Generated from Live-Generated content | category field enforced at point-of-export via VS Code extension |
✓ Covered |
| Ensure disclosed content matches shipped assets | SHA-256 hash verification — any modification is flagged as tampered | ✓ Covered |
| Block non-compliant assets from shipping | GitHub Actions build gate — PR blocked if scan fails | ✓ Covered |
Workflow: Tag assets at export → run
originguard scan in CI → copy steam_disclosure.disclosure_statement to your Steamworks page. Done.
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EU AI Act — Article 50
Effective August 2, 2026 · Applies to all AI systems targeting EU users
What Article 50 requires
Article 50 of the EU AI Act imposes transparency obligations on deployers of AI systems. For game studios, this translates to four concrete requirements:
- AI-generated content must be labelled as such in a machine-readable format.
- The labels must be technically robust — not easily removable by downstream processing.
- Deployers must retain documentation about AI systems used and the content generated.
- Documentation must be available for regulatory audit on request.
Scope: Article 50 applies if your game is sold or distributed in the EU — regardless of where your studio is incorporated. Penalties for non-compliance can reach €15M or 3% of global annual turnover.
How OriginGuard satisfies Article 50
| Obligation | OriginGuard Output | Status |
|---|---|---|
| Machine-readable synthetic content labels | eu_ai_inventory.tools[] — structured JSON per tool per category |
✓ Covered |
| Technically robust labelling (tamper-evident) | SHA-256 hash in .origin sidecar; any asset modification invalidates the tag |
✓ Covered |
| Retain documentation for audit | Master_Disclosure.json uploaded as a CI artifact with 90-day retention |
✓ Covered |
| Identify AI systems used | tool and category fields per asset in the provenance record |
✓ Covered |
Audit readiness: If a regulator requests your AI content documentation, point them to your latest
Master_Disclosure.json CI artifact. Every field maps directly to Article 50 requirements.
Full compliance coverage at a glance
| Regulatory Obligation | Regulation | OriginGuard Field |
|---|---|---|
| Disclose AI-generated player-facing content | Steam AI Policy | steam_disclosure.disclosure_statement |
| Distinguish Pre-Generated vs Live-Generated | Steam AI Policy | .origin.category |
| Hash-verified asset integrity | Both | .origin.sha256 |
| Machine-readable synthetic content mark | EU AI Act Art. 50 | eu_ai_inventory.tools[] |
| Retain documentation for regulatory audit | EU AI Act Art. 50 | Master_Disclosure.json CI artifact |
| Identify AI systems and tools used | EU AI Act Art. 50 | .origin.tool |
| Block non-compliant assets from shipping | Both (best practice) | GitHub Actions build gate |
| Internal audit trail with CRITICAL warnings | Both (best practice) | integrity_report |
Disclaimer: This guide reflects our interpretation of the regulations as of May 2026. OriginGuard licenses include compliance updates throughout your license term — if Steam or the EU AI Act updates their requirements, OriginGuard updates too. For legal advice specific to your studio, consult a qualified lawyer.