Steam’s policy flaws exposed by Call of Duty’s generative AI announcement

A few weeks back, a new AI generated content disclosure appeared on the Call Of Duty Steam page, reading “our team uses generative AI tools to help develop some in game assets”. This followed several months of community speculation over whether the FPS was using such tools to fever-dream up cosmetics, and a Wired report (paywalled) in which an anonymous artist alleged that the ‘Yokai’s Wrath’ premium pack used genAI assets, via PC Gamer.

As a disclosure, it’s better than nothing, but only barely. While the admission of any GenAI presence is useful to those of us who would rather avoid it entirely, the description “help develop some in game assets” tells us very little. So who’s at fault here? Are Activision skirting Valve’s requirement to be purposely vague, or do Valve’s requirements themselves invite vagaries?

First, some background. I first encountered COD community GenAI suspicions in a Twitter thread about a zombie Santa. The loading screen featured a Crypt Keeper-esque Kris Kringle with six fingers. GenAI is famously inept at counting digits, although I did see some pushback at the time from people who reckoned the ‘extra’ finger was zombie flesh sloughing off the bone. No such claims were made about this promotional image, however, which shows a gloved hand with six fingers, plus a bonus thumb.

Then, there was the Hard Breakup calling card. “I am so disappointed,” wrote Reddit user Poodonkus last year. “I had heard of a cool pin-up style calling card for completing this challenge, but I wasn’t expecting to find…glaring hallmarks of an unrefined AI generated image.”

“Treyarch, look into this,” they continued. “I don’t deserve to be rewarded with half-hearted soulless fake art after completing a challenge this difficult. Remake this calling card, hell trace it if you have to. But give us players more respect than this.”

I can’t know whether Poondunkus’s disappointment with Hard Breakup was an aesthetic issue or because the GenAI hallmarks reveal a lack of human touch and care, but such images say nothing if not “we don’t value this enough to design it ourselves, but we expect you to value it enough to grind for it”. And this is where, I think, we run into the limits of Valve’s policy and the leeway it gives publishers to be ambiguous to the point of uselessness.

“Our team uses generative AI tools to help develop some in game assets,” reads Activision’s disclosure. What does “help” mean here? What does “develop” mean? What about “some”? Howsabout “assets”? Do they mean the loading screen, which is tacky and diminishes the game’s overall look but is otherwise comparatively inconsequential to players? Or do they mean the calling card, which evidently has value to some as a digital object they’ve worked to obtain? Or do they mean entire maps, skins, weapons? Which genAI tools have they used, exactly?

Activision’s Steam disclosure could mean anything from loading screens to levels, so let’s recap what it is that Valve’s policy actually asks for here. The policy change was made public last January, following Valve taking “some time to learn about the fast-moving and legally murky space”. It asks game submissions to detail “any kind of content (art/code/sound/etc) created with the help of AI tools during development.”

Also publicly available is the following high-level description of the content survey publishers and developers are required to submit alongside their game.

Anyone who submits a game to Steam is required to fill out a form that includes sections on “general”, “mature”, and “generative artificial intelligence content”. That last section is split into two categories: pre-generated and live-generated. These sections are preceded by the following description:

“If your game uses AI services during development or incorporates AI services as a part of the product, this section will require you to describe that implementation in detail.”

Here’s said section from the actual form, which was passed to us by a developer.

As you can see, the overwhelming majority of the section focuses on the details of live-generated AI content, with comparatively little required for what Valve call pre-generated. The granular tickbox that lists specific assets like text, textures, voice, and music is reserved for live-gen only, whereas pre-gen is relegated to a single tick and description form at the bottom. The description is the only part of the genAI disclosure that players are able to read.

And this is how you end up with Activision getting away with “our team uses generative AI tools to help develop some in game assets”. Based on the form, there’s no requirement they publicly specify what these assets actually are, and so players are forced to contend with that most insidious side-effect of GenAI: the constant vigilant paranoia that comes from not knowing whether something is or isn’t created by another person. Am I looking at GenAI art, or just art I don’t like? Is this card I’ve worked so hard to get actually the work of a developer?

The form also notes that Valve will provide players with Steam Overlay tools to highlight “inappropriate, or copyright infringing” generated AI material. It’s not clear what these are, but it’s easy to imagine Steam support staff facing a rash of false positives from players who have been given incomplete information about how a game uses generated AI. The topic of generative AI copyright infringement is vast and knotty, even with full disclosure about the materials used for generation – if you’re interested, you could start by reading Mike Cook’s piece on the legalities of generative AI from last year.

We might contend that generating most assets is less harmful than stealing entire skin designs from artists, as COD allegedly has multiple times. We could say that, as yet, this doesn’t present enough of a sweeping issue for Valve to take another look at their policy – as Aftermath’s Nathan Grayson notes, “those who analyze Steam and similar platforms for a living aren’t sounding the alarm bells about an AI slop flood just yet. The bigger issue Steam developers face is the sheer number of high-effort, good games that come out on a daily basis”.

Still, as it stands, Valve’s disclosure policy seems overwhelmingly tailored towards covering their own legal bases, as opposed to keeping players informed about what aspects of their games are AI generated. And if Activision are content to use generative AI tools – even while laying off quadruple-digit numbers of humans – then why are they being so cagey about its actual use cases? If GenAI is ‘here to stay’ – if it’s ‘the future’, as its evangelists are so keen to repeat ad parrotitum – then why not tell us exactly what that future looks like?