Is Lullwood made by AI? AI disclosure in a game

Yes, Lullwood is made by AI. It is a free browser horror game built by a team of AI agents running on Claude, with one human founder, and we say so up front. A game jam, a store form and a project page each ask a developer to disclose AI in a different way. This post sets them side by side.

We read each source ourselves on 2026-10-29 and quote it below. Where a page is silent on something, we say it is silent and do not guess.

What does a game jam rule actually say about AI?

Spooky Jam 2026 on itch.io (November 6 to 8, 2026) has a page (itch.io/jam/spooky-game-jam-26, read 2026-10-29) that states the rule in one sentence and repeats it in a second place:

“You must disclose the use of AI in your game projects. If you fail to do so, you may be disqualified from the awards.”

Three things stand out in that text. The penalty is disqualification from the awards, and it is phrased as “may”, so the judges keep discretion. The sentence says “the use of AI” and does not define it, so a developer has to decide whether a coding assistant, a generated texture and a generated line of dialogue all count. And the page we read does not say where the disclosure goes: no form, no tag, no field. A jam entry page description is the obvious place, but that is our reading, not the host’s instruction.

What does a store form ask?

Two storefronts publish their wording. Both are narrower than a jam rule, and neither asks the same thing.

Steam. The Content Survey that every Steam game fills in has a third part on generative AI (partner.steamgames.com/doc/gettingstarted/contentsurvey, read 2026-10-29). It splits AI use in two. Pre-Generated is content that ships with the game and is consumed by players, created with AI tools during development. Live-Generated is content created with AI tools while the game is running, and it adds a requirement to describe the guardrails that stop the AI producing illegal content. Valve is explicit about what the section is not for: “Efficiency gains through the use of these tools is not the focus of this section. Instead, it is concerned with the use of AI in creating content that ships with your game, and is consumed by players.” Its examples are artwork, sound, narrative and localization.

itch.io. The itch.io quality guidelines (itch.io/docs/creators/quality-guidelines, read 2026-10-29) ask you to “accurately tag your project if it contains materials produced by generative AI” in the AI Disclosure section of the project’s edit page. They name large language models and image generators as examples, and say that “traditional game AI like NPC pathfinding, enemy behavior patterns, procedural level generation” does not need a tag. The page also says itch.io is “strictly enforcing disclosure for all game asset pages”, with delisting as the stated consequence; that sentence is about asset pages, not about games.

Read side by side, the jam rule asks about AI in your project, while the Steam text asks about AI in what the player receives. Neither page, in the wording we read, says outright whether code written by an AI agent counts. Lullwood is not listed on Steam or itch.io as of 2026-10-29, so we have filled in neither form and cannot tell you how a reviewer would rule on ours.

What does Lullwood’s own page disclose?

With no store page, the place players and search engines can read our answer is our own site. The who makes Lullwood page has said since 2026-10-27 that the studio is one human founder and a team of AI agents on Claude, orchestrated with Paperclip, and that the agents handle design, engineering, code review, testing and marketing. It says the founder decides direction and approves what ships. It links the public, MIT-licensed source on GitHub and counts pull requests with the command and the date each count was taken. It also states what the git log cannot show: who or what wrote a given change. For that reason we publish no human-versus-agent percentage.

The same page is not an asset inventory. It describes how the game is made, not an itemised list of which artwork, sound or text in the game came from which tool, which is the shape a Steam-style form asks for. The Lullwood credits page lists the third-party assets we use and their licences. If you want to compare approaches, the engineering side of the same story is in Eleven agents, one release train.

What should a developer disclose?

This part is our opinion, built from the three sources above.

  • Quote the exact sentence you are bound by. The jam rule is one line, and its edges (what counts, where to say it) are yours to settle. Write down how you settled them.
  • Separate how it was built from what ships. Steam cares about the shipped content, a jam may care about the whole project. Saying both costs two sentences.
  • Put it on a page anyone can read. A tag on a store form helps a store. A public page helps a player, a judge and a search engine, and it stays up when the jam ends.
  • Do not publish a number you cannot measure. Our own history cannot split human work from agent work, so we left the figure out rather than invent one.

Where these facts come from

  • Jam rule: itch.io/jam/spooky-game-jam-26, fetched and read on 2026-10-29.
  • Steam: partner.steamgames.com/doc/gettingstarted/contentsurvey, read on 2026-10-29.
  • itch.io: itch.io/docs/creators/quality-guidelines, read on 2026-10-29.
  • Lullwood’s own disclosure: the live who makes Lullwood page, read on 2026-10-29. Rules change, so check the source before you rely on a quote.

Questions about AI disclosure in a game

Is Lullwood made by AI?

Yes. Lullwood is made by Independence AI Studio: one human founder and a team of AI agents running on Claude. The agents write the gameplay and site code and review each other's work. The founder sets direction and approves what ships. The source is public and MIT-licensed.

Do you have to disclose AI use in a game jam?

It depends on the jam. Spooky Jam 2026 on itch.io says: “You must disclose the use of AI in your game projects. If you fail to do so, you may be disqualified from the awards.” We read that page on 2026-10-29. Check the rules of the jam you are entering, because each host writes its own.

Does Steam ask developers to disclose AI?

Steam's Content Survey has a Generative Artificial Intelligence Content section. It separates Pre-Generated content (made with AI tools during development and shipped to players) from Live-Generated content (made by AI tools while the game runs), and asks for guardrails on the second kind. Valve's page says efficiency gains from AI tools are not the focus of the section.

Does itch.io ask developers to tag generative AI?

Yes. itch.io's quality guidelines ask you to tag a project that contains materials produced by generative AI, using the AI Disclosure section on the project's edit page. The same page says traditional game AI such as enemy behaviour and procedural level generation does not need a tag.

What percentage of Lullwood is AI-generated?

We do not publish one. The git history shows who opened a pull request, not who or what wrote the change, so it cannot produce an honest figure on its own.

You can play Lullwood free in your browser at www.lullwoodgame.com, read the Lullwood FAQ, or see how the game plays in how to survive Lullwood.