AI Usage assessment
A technical-legal audit of AI tools in your game development pipeline, covering regulatory compliance, platform rules, and IP risks for studios shipping AI-powered features or AI-generated content.
What our clients face
AI-generated assets in production
If your studio uses AI-generated assets — art, music, dialogue, or code produced by tools like Stable Diffusion, Midjourney, or neural audio networks — you need clarity on who owns the output and whether those assets are protectable under copyright law in your target jurisdictions.
Player-facing AI features
Games shipping with adaptive difficulty, AI chat companions, AI-powered content moderation, or other player-facing AI features may require specific disclosures before platform approval. Apple and Google have updated their review guidelines to address AI-powered features and AI-generated content within apps, and non-compliance with these contractual terms can delay or block your release.
Custom models and the EU AI Act
Studios training custom models and making them available beyond internal use may face obligations under the EU AI Act's provisions on general-purpose AI models, including transparency and technical documentation requirements directed at GPAI providers. Even studios using third-party AI tools need to understand how the Act's transparency obligations for AI-generated content (Article 50) could apply to their shipped products.
UAE AI governance
The UAE has published soft-law AI governance instruments — including the National AI Strategy 2031, Dubai AI Ethics Guidelines, and Abu Dhabi AI Ethics Principles — which, while not yet binding legislation comparable to the EU AI Act, signal the regulatory direction for companies operating out of Dubai or Abu Dhabi and may influence future enforceable rules.
Our approach
Technical-legal audit
We treat AI usage assessment as a technical-legal audit. The engagement starts with a detailed mapping of every AI touchpoint in your development pipeline and shipped product. We identify the specific models and tools in use — commercial APIs, open-source models, fine-tuned systems — and trace the data flows from training inputs through to player-facing outputs.
Three dimensions of assessment
For each touchpoint, we assess three dimensions: regulatory compliance, platform compliance, and intellectual property risk.
Regulatory compliance
We determine whether any of your AI systems trigger the EU AI Act's transparency obligations under Article 50 (covering AI-generated content, emotion recognition, and deepfakes) or fall within the high-risk categories defined in Annex III, and we distinguish between obligations that apply to GPAI model providers versus those that apply to downstream deployers like game studios. We also evaluate your posture against UAE soft-law AI governance guidelines — non-binding today, but relevant for studios establishing operations in UAE free zones alongside the data protection obligations that DIFC and ADGM do enforce.
Platform compliance
We review your current App Store and Google Play submissions against their latest developer agreement terms on AI-powered features, AI-generated in-app content, and disclosure expectations — contractual obligations that carry real consequences (submission rejection or removal) even though they are platform policies rather than statutory requirements.
Intellectual property risk
We analyze the ownership status of AI-generated assets — art, dialogue, music, code — under the copyright frameworks of your key markets, flag training data licensing gaps, and identify where third-party IP claims could arise. We also review your internal documentation: data provenance records, usage policies, and — if your studio develops or distributes its own AI models — the technical documentation and model cards that the EU AI Act requires of GPAI providers.
Stages of work
Technical intake session
We begin with a technical intake session where your development leads walk us through the AI stack: what tools are used, at which pipeline stages, and what data they consume. We request access to relevant model documentation, training dataset manifests, and any existing compliance materials.
Regulatory analysis
Our team conducts a regulatory analysis covering the EU AI Act — with attention to the Act's provisions on general-purpose AI models (Chapter V), transparency obligations for AI-generated content (Article 50), and the distinction between provider-level and deployer-level requirements that determines which rules actually apply to your studio. We also map your exposure against UAE soft-law AI governance guidelines and any data protection obligations in your UAE operating jurisdictions, plus jurisdiction-specific rules in your other distribution markets.
Platform-readiness review
A platform-readiness review maps your current store listings and metadata against Apple and Google developer agreement terms on AI-powered features, content-generation policies, and disclosure expectations, including an assessment of whether AI-driven content features could affect age-rating considerations as platform and rating-body policies continue to evolve.
IP and data-rights assessment
An IP and data-rights assessment evaluates copyright protectability of your AI-generated assets, reviews training data licenses for gaps or conflicts, and flags open-source model license terms that could affect your commercial use.
Structured result
The deliverable is a structured report with a risk matrix, specific compliance gaps, and an actionable remediation plan — covering everything from required platform disclosures and documentation improvements to licensing corrections and model-governance policies your team can implement before launch.
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