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Review every AI-generated game asset on three separate tracks: copyrightability (what human-authored expression exists), permission and infringement risk (what the tool, source material and third parties allow), and platform compliance (what each storefront requires you to disclose and promise). A favorable result on one track does not answer either of the others. Under the U.S. Copyright Office’s January 29, 2025 guidance, prompting alone is not enough to make an output human-authored, while meaningful human selection, arrangement or modification may contribute protectable expression. Steam still evaluates AI output under the same content and rights standards as other content, and asks developers to disclose both pre-generated and live-generated AI content.
The practical method is an asset-level record: identify the file and build, preserve its provenance and applicable terms, describe the human contribution, screen for recognizable third-party material, map the result to each platform’s disclosure rules, then approve, replace or escalate. This guide covers U.S. copyright guidance and Steam documentation available through October 13, 2026; other countries, storefronts, tools and model versions can impose different rules.
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The three questions every review must answer
Do not label an asset simply “AI” or “not AI.” Record separate answers to three questions so that a weakness in one area is not hidden by a strength in another.
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The U.S. Copyright Office’s Copyrightability of Generative AI Outputs, Part 2, published January 29, 2025, says an output may be protected when a human author determines sufficient expressive elements. The Office identifies, among other situations, human-authored work that remains perceptible in the output and creative human arrangements or modifications. It also says that AI assistance, or the inclusion of AI-generated material in a larger human-generated work, does not automatically prevent copyrightability.
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Merely supplying prompts is not enough under that guidance. Iterating prompts, choosing a result or accepting a model’s unedited image should not be described as proof that the user authored every expressive detail. Instead, document the actual human decisions: drawing or modeling, editing pixels or geometry, composing layers, arranging assets, writing or rewriting text, directing a recording, or making other creative modifications. Copyrightability is a U.S. legal question and does not establish the result in another jurisdiction.
2. Do you have permission to use all included material?
Copyrightability and permission are different. An output with little or no human-authored expression may still contain material that creates contractual, copyright, trademark, publicity, privacy or other risk. Conversely, an asset with substantial human contribution can still violate a third party’s rights or the tool’s license.
Review the terms that applied when the asset was made, including the AI service or model, any marketplace or contributor agreement, source references and the game’s own publishing contracts. Check commercial use, modification, redistribution, attribution, sublicensing, ownership language, indemnities, prohibited inputs and restrictions on generated outputs. Terms can change by date, account tier, geographic region, model version or product, so preserve the actual version and a copy of the terms you relied on.
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3. Does the release satisfy the platform’s rules?
Storefront disclosure is an operational requirement, not a grant of rights. Steam’s Content Survey asks developers using AI services during development or in the product to describe the implementation. Steam says it evaluates AI output under the same standards as non-AI content, including whether the game meets promises not to include illegal or infringing content and whether its content matches its marketing.
Steam’s survey and review do not waive those rules. A completed survey does not prove that an asset is licensed, copyrightable or lawful. Review every other intended storefront independently; the Steam documentation does not establish another platform’s policy.
What Steam means by pre-generated and live-generated AI content
Classify the implementation before completing the survey. The classification affects what you disclose and, for live generation, what safeguards you must explain.
| Category | What it is | Examples | Review implication |
|---|---|---|---|
| Pre-generated content | AI-created material made during development that ships with the game and is consumed by players. | Artwork, sound, narrative and localization included in the build. | Inventory the shipped files, retain their provenance and describe the use in Steam’s Content Survey. |
| Live-generated content | AI-created material generated while the game is running. | A runtime system producing dialogue, images, music or other content in response to play. | Describe the implementation and the guardrails intended to prevent illegal output, as Steam requests. |
When an update changes the shipped files or the way generation works, revisit the survey and follow Steam’s current instructions for updating an answer. Steam notes that some answers cannot be edited after the build and store page are approved without contacting Steam Support. Plan for that constraint rather than treating the first submission as permanent.
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A game-wide statement such as “we used AI for art” is too vague to support a release decision. Use one record for each material asset or coherent asset batch, then roll decisions up to the build and platform.
Required identity fields
- Stable asset ID: a name that will not change when the file is re-exported.
- File and version: path, hash or repository revision, format and the date of the reviewed version.
- Asset type: sprite, texture, model, animation, voice, music, sound effect, text, localization or other content.
- Intended use and location: scene, menu, character, promotional image, downloadable content or other placement.
- Player access: whether the asset is visible or audible to players, generated at runtime, used only in development or present in marketing materials.
- Target build: the release candidate, branch or patch in which it appears.
Origin and tool fields
- Name the person, employee, contractor or vendor who created, selected or revised the asset.
- Record the AI tool, model or service, account or plan where relevant, model version and dates of use.
- Describe the workflow stage where AI contributed: ideation, draft generation, editing, upscaling, voice conversion, localization or another function.
- Preserve source project files, layer histories, mesh or timeline files, and prompt or iteration records where appropriate. A prompt log is evidence of process, not automatic proof of ownership.
Decision fields
- Summarize the human-authored expressive elements and identify which portions came from the model or another source.
- List the terms and permissions reviewed, their effective dates and any unresolved restrictions.
- Record third-party screening results, reviewer, review date, decision, rationale and any replacement or escalation.
- Link the decision to the final build and to the platform disclosure used for submission.
Step-by-step review workflow
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Freeze the version you are reviewing
Export or commit the exact file intended for the release candidate. Give it a stable ID and record a hash or repository revision. A review of an earlier concept does not clear a later variant that contains different faces, logos, lyrics, dialogue or textures.
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Map where players and marketing will encounter it
List every in-game location, downloadable package, user interface element, cinematic, trailer, screenshot and store-page image that uses the asset. Include hidden or conditional content and runtime-generated variants. Marketing promises must match the content that ships.
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Record the complete creation chain
Identify human contributors, tools, model and version, dates, inputs, edits, exports and intermediaries. If a contractor supplied the asset, retain the contract and confirm that it covers the intended game, platforms, territories, modifications and sublicenses.
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Capture the governing terms for the date of use
Save the service and model terms that applied when the generation occurred, plus marketplace, stock, font, sample, voice, music and contributor licenses. Check whether the terms permit commercial use, redistribution in a game, modification, sublicensing to platform users, attribution and use in promotional materials. Flag a term you cannot verify instead of assuming a broad license.
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Describe human creative contribution
Separate human-created portions from model-generated material. Explain who selected expressive details, arranged components, edited pixels or geometry, rewrote text, synchronized sound, or integrated the asset into a larger original work. Keep working files that show those choices. Do not claim that prompt iteration alone establishes copyright.
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Screen for recognizable third-party material
Look and listen for characters, logos, artwork, photographs, music, lyrics, voices, names, likenesses and distinctive styles that could identify another rights holder. Check whether the game’s use is licensed and whether the asset also appears in advertising or user-facing generation. Automated similarity tools can prioritize manual review, but they are not legal determinations.
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Assess unresolved provenance
Mark unknown training or source provenance, unexplained stock fragments, uncertain voice consent, conflicting contributor statements and terms that do not address redistribution. A lack of evidence is a risk signal, not evidence that no restriction exists.
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Map the result to Steam’s survey
Decide whether the asset is pre-generated, live-generated or both in different parts of the game. Describe the implementation accurately. For live generation, document the filters, moderation, blocklists, human review, reporting, logging, rate limits or other guardrails that actually operate; do not promise controls the build does not provide.
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Compare the submitted build, store page and promises
Before submission, check that the reviewed files are in the build, that trailers and screenshots use the same approved assets, and that the survey describes the shipped implementation. Steam’s prerelease review evaluates AI output under the same standards as other content and checks that the game meets its rights and content promises.
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Approve, replace or escalate
Assign a named reviewer and date. Approve when provenance, permissions, human contribution and platform treatment are documented; replace when an equivalent low-risk asset is available; escalate high-impact uncertainty to qualified counsel or the relevant rights holder. Record the rationale and retain superseded versions so the decision can be audited.
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How to evaluate human authorship under U.S. guidance
The Copyright Office’s approach is fact-specific. Ask what expressive choices a person actually made and what remains perceptible in the final work.
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A person’s original drawing, photograph, writing, performance or other expression may remain visible or audible after AI assistance. Document the original files, the transformation steps and the portions that survived. The AI contribution does not automatically erase the human contribution, but the scope of any protection follows the human-authored expression rather than an unsupported claim over the entire output.
Creative selection, arrangement or modification
Human choices can matter when they determine the expressive arrangement or materially modify the result. Keep layer files, timelines, node graphs, edit histories and version comparisons that show those choices. Mechanical cleanup, format conversion or an uncreative acceptance decision may provide little evidence of authorship; do not characterize every edit as creative authorship.
AI material inside a larger human work
The Office states that including AI-generated material in a larger human-generated work does not automatically bar copyrightability. Identify the larger work’s human-created structure and the AI portions separately. For a game, that can mean documenting the human-authored level design, character direction, dialogue revisions, editing and composition instead of asserting that every generated texture or line of text is independently protected.
What the guidance does not decide
It does not decide the status of a named asset, authorize a provider’s training practices, grant permission to use recognizable material or establish rules outside the United States. It also does not promise that a particular amount of editing creates a copyright. When registration, enforcement or ownership is important, obtain advice on the facts and jurisdiction involved.
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Permission and infringement checks that are easy to miss
Tool and model terms
Read the exact terms for the product and model version used. Look for ownership language that differs from a license to use, clauses reserving provider rights, output restrictions, indemnity exclusions, prohibited content rules, attribution duties and limits on commercial or downstream use. A plan that allows personal experimentation may not grant the rights needed for a commercial game distributed on multiple platforms.
Inputs and reference material
Record images, audio, text, 3D scans, photographs, voices and other material supplied to the system. Confirm that the team had permission to upload and transform each input. Do not assume that changing an input’s format or using it only as a reference removes its restrictions.
Third-party identity and endorsement signals
Review names, likenesses, voices, logos, uniforms, fictional characters and distinctive product designs. Even when a copyright claim is uncertain, trademark, publicity, passing-off or contractual concerns may remain. Obtain permission or replace the asset when the game could imply sponsorship, endorsement or association.
Music, voice and localization
Check samples, lyrics, translations, voice models and performance permissions separately from the visual asset review. A generated voice that resembles an identifiable performer, or a translation based on protected text, needs its own provenance and rights analysis. Include menu, trailer and social-media uses in the same review.
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Similarity tools and human review
Image, audio, text and code similarity searches are useful triage. They can identify candidates for investigation, but a similarity score does not establish copying, permission or liability. Preserve the query, date and reviewer’s reasoning so the result is reproducible.
Steam submission and release timing
Steam’s Content Survey asks about AI services used during development or in the product. Answer for the implementation that will ship, not an earlier prototype. Pre-generated content includes AI-made artwork, sound, narrative and localization shipped for players; live-generated content is created while the game runs and requires information about safeguards against illegal output.
Steam says its prerelease review evaluates AI output the same way it evaluates non-AI content and checks that the game meets promises not to include illegal or infringing content and that it matches marketing materials. Disclosure is therefore part of an accurate submission, not a safe harbor.
Steam’s Review Process documentation gives a typical review period of 3–5 business days and recommends submitting at least 7 business days before release so changes can be made. These are platform estimates and can change, so check the live documentation when scheduling. Some survey answers cannot be edited after the build and store page are approved without contacting Steam Support; revisit the survey whenever content or implementation changes and follow Steam’s current update instructions.
Comparing two candidate assets
When two assets serve the same design purpose, compare the evidence and operational burden rather than choosing solely on visual quality.
| Comparison axis | Questions to ask | Preferred evidence |
|---|---|---|
| Human contribution and documentation | Which expressive elements did a person create, select, arrange or modify? | Source files, edit history, layer or timeline records and a concise contribution statement. |
| Provenance and rights certainty | Can you identify the tool, model, inputs, contributors, terms and permissions for the exact version? | Archived terms, contracts, receipts, source references and dated review notes. |
| Similarity and third-party material risk | Does the asset resemble protected characters, logos, artwork, music, voices or other identifiable material? | Manual review supported by documented similarity searches and permission records. |
| Platform disclosure and operations | Is it pre-generated or live-generated, and what disclosure or guardrails are required? | Survey answers tied to the build, implementation notes and tested controls for live generation. |
An asset with more human editing is not automatically safer if its source material is unexplained. An asset with clear permissions still needs accurate platform disclosure. Use the comparison to prioritize review, not as a substitute for legal analysis.
Common failure modes and fixes
“The model terms say I can use outputs, so every output is cleared”
Why it fails: A service license may not cover third-party material appearing in an output, contributor rights, publicity rights or the rights needed for platform redistribution.
Fix: Archive the applicable terms, investigate inputs and recognizable elements, and document permissions or replacement decisions asset by asset.
“We edited it, so it is definitely copyrighted”
Why it fails: The U.S. guidance asks whether a human determined sufficient expressive elements; it does not turn every technical or cosmetic edit into protected authorship.
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Fix: Describe the creative choices and preserve evidence. Separate the human-authored portions from model-generated material in ownership and registration decisions.
“We disclosed AI to Steam, so Steam approved our rights”
Why it fails: Steam disclosure is not a waiver of content rules or a license. Steam still checks rights promises and marketing accuracy.
Fix: Complete the survey accurately, retain the underlying rights record and make the build and store page match the submission.
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Why it fails: Hidden, conditional, downloadable or promotional content can still reach players or appear in a store listing. Runtime generation can also create new risk after release.
Fix: Inventory every shipped and player-accessible path, including marketing and downloadable content, and classify runtime systems separately.
“A similarity scanner found nothing, so there is no infringement risk”
Why it fails: Search coverage is incomplete, and similarity tools do not decide copying, permission or liability.
Fix: Use scans for triage, then conduct a documented human review and escalate recognizable or high-impact results.
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Why it fails: Steam says some answers cannot be edited after approval without contacting Support, while later content or implementation changes can make the answer inaccurate.
Fix: Review the survey at each release candidate, submit with schedule margin and follow Steam’s current update process when the implementation changes.
Scope, records and escalation
This workflow is a practical risk-management method, not an official legal checklist. The cited U.S. Copyright Office materials do not resolve a named asset, a provider’s current license terms, whether a training set was authorized or the rules of another country. Steam documentation does not establish the policies of other storefronts.
Keep the asset record with the release evidence for as long as your contracts, platform obligations and legal-retention policy require. Escalate when an asset is central to the game, prominently marketed, likely to be recognized, based on an identifiable person’s voice or likeness, generated from uncertain inputs, or governed by terms you cannot interpret confidently. A qualified lawyer or rights holder can address the specific jurisdiction and facts.
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The Copyright Office’s AI study page reports receiving more than 10,000 comments by the December 2023 deadline. That figure shows the scale of participation in the study; it is not an infringement rate, a measure of AI-asset use or proof of public agreement.
Quick Recap
Release-ready checklist
- Every shipped AI-assisted asset has a stable ID, final version and target build.
- The record names the human contributors, tool or model, version, dates and workflow stage.
- Applicable tool, model, marketplace and contributor terms are archived for the date of use.
- Inputs and source material have documented permission or a recorded escalation.
- Human-authored expression and model-generated portions are described separately.
- Recognizable characters, logos, artwork, music, voices, likenesses and other third-party material have been reviewed.
- Similarity searches, if used, are treated as triage rather than legal conclusions.
- Steam content is classified as pre-generated, live-generated or both where applicable.
- Live-generation guardrails described to Steam exist in the release build.
- Survey answers, store-page text, trailers, screenshots and the final build tell the same story.
- Uncertain, high-impact assets have a named reviewer and counsel or rights-holder escalation where needed.
- The team has a process to recheck terms, assets and platform disclosures after updates.
Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.
