Steam requires disclosure of whether a game contains “AI-generated” content, but is somewhat vague about whether “content” in this case is limited to 3d models, 2d images, video, and sound or whether it also includes code generated by an LLM. A somewhat recent update to Steam’s developer documentation clarifies that it does not cover “efficiency gains” through the use of AI-powered development environments, which many have interpreted to mean that LLM-generated code is an exception.
Regardless of whether carving out an exception for code was actually the intent of the clarification, I argue that such an exception is not tenable.
Below is some code that I have asked an LLM to generate:
<svg width="200" height="200" viewBox="0 0 200 200" xmlns="http://www.w3.org/2000/svg">
<polygon points="100,20 140,120 60,120" fill="red" />
<polygon points="40,150 80,70 120,150" fill="blue" />
<polygon points="160,150 120,90 80,150" fill="green" />
</svg>
Copy and paste this into a file with a .svg extension, open that file in a web browser, and you will see three colored triangles. This code generates an image, but it also is the image. This is an AI-generated image. It gets worse, though:
<div style="position: relative; width: 200px; height: 200px;">
<div style="position: absolute; width: 0; height: 0; border-left: 40px solid transparent; border-right: 40px solid transparent; border-bottom: 100px solid red; top: 20px; left: 60px;"></div>
<div style="position: absolute; width: 0; height: 0; border-left: 40px solid transparent; border-right: 40px solid transparent; border-bottom: 80px solid blue; top: 70px; left: 40px;"></div>
<div style="position: absolute; width: 0; height: 0; border-left: 40px solid transparent; border-right: 40px solid transparent; border-bottom: 60px solid green; top: 90px; left: 80px;"></div>
</div>
Same deal, except the file should have a .html extension instead of a .svg extension. HTML is the language of the web. It (alongside CSS) controls what websites look like when the browser renders them. If you want to get an idea of just how big of an impact the code of a webpage has on what you’re seeing when you view it, try this:
What you see after doing that is what the page looks like with the “styles” removed. In other words, all of the code that controlled the appearance of the page has been disabled. Code was responsible for sizes, positions, colors, borders, shadows, shapes, animations, interactions, and a substantial portion of the images. The code is the web page. It is the source of the web page’s artistic qualities: if you look at a website whose code was generated by an LLM, you are looking at “AI art.”
Websites are an easy example, but artistic qualities or no, a website’s code is typically instrumental to whatever purpose the website serves. In a game, the code is the art. A video game without code isn’t a video game, and video games are often criticized when the “video game” part doesn’t add anything meaningful to the experience.
Few games make this clearer than Undertale, widely considered one of the best video games of all time. Undertale’s artistic value is delivered almost entirely by its writing, music, and code. Here’s a list of a few of the memorable artistic choices in the game:
There are hundreds of examples I’ve omitted. All of it is code. Every little animation, every decision about where to put sounds and music, every Easter egg, every particle effect, every game mechanic, all of it. Code.
Websites and Undertale were the easiest examples I could reach for, but really there are so many examples I could have chosen. Ever heard of the demoscene? That’s a community where people make entire animated spectacles using nothing but code. There’s also Shadertoy, a website where people have taken a single tiny piece of the modern game development graphics pipeline and made art using only that. Minecraft’s rolling hills and winding caves aren’t drawn by an artist’s hand but indirectly by the programmer: specialized code creates unique terrain with each new game you start.
The reason it initially made sense to make a distinction between LLM-generated code and AI-generated images or sounds is that the latter can largely be created in one prompt while the former still required the involvement of a human programmer. If an LLM generates all the code but a programmer makes all the decisions, then surely we can still consider the result human-authored?
The problem with this view is that it’s based on an outdated understanding of LLM limitations. Unity recently announced Unity Spark, an LLM-based game authoring tool that can generate an entire game from a handful of prompts. Notably, it doesn’t appear to rely on “AI art” in the code-exclusionary sense, but instead composes games from collections of pre-made assets presumably made by human authors. Should games made with this tool be labeled as AI-generated on platforms that require it? I think it’d be difficult to argue that the answer is “no.”
I hope I’ve made it clear why excluding code from an AI content labeling system doesn’t make a whole lot of sense. Why then might Steam choose to do so? The short answer is they have to, otherwise every single game developer using a modern version of Unreal Engine would need to mark their games with the AI label.
Game engines are often thought of as tools, but in reality a game engine is both a tool and a set of components that eventually end up in the final game. Modern games load polygon data, draw 3d shapes on screen, render various lighting effects, animate models, simulate basic physics, and more. All of these things are driven by code written by engine developers or by their LLM-powered “agents.” Even games that don’t use engines will often still rely on a substantial amount of code written by others, much of it “poisoned” by LLM authorship.
It’s probably not fair to pick on Unreal Engine like this, but it makes for a good example thanks to the public statements by Tim Sweeney, CEO of the company responsible for developing it. Sweeney has publicly confirmed that Unreal Engine is developed using LLM-generated code, while publicly criticizing Valve for Steam’s AI-generated content disclosure policy. It’s easy to guess that Unreal Engine’s authors might be worried about what an exhaustive AI-generated content disclosure policy might mean for games developed with Unreal.
Even if the major engines and game libraries all promised to never use AI-generated code, or if Steam carved out an exception for a game’s dependencies, the poorly-kept secret in gamedev right now is that there has already been a widespread switch to using LLMs. The view that an LLM-coded game doesn’t “count” as AI-generated art is common among programmers, and both industry surveys and my industry connections confirm that LLM usage when writing game code is already ubiquitous.
Clearly there is a mismatch between the expectations of players, the expectations of game developers/distributors, and the reality of what it means to generate code with AI. As LLM-based coding tools improve, it will become increasingly difficult to rely on the code/asset distinction when marking and filtering AI-generated content. Soon the gaming community will be forced to decide what it wants the future of game development to look like.