Tales of Legendary Lust: Aphrodisia is an adult role-playing game available on Steam. Think of it like an indie developer’s take on the original Baldur’s Gate games, but lewd. The game launched on Steam on Sept. 14th, and it features branching narrative choices, hand-painted artwork, and "erotic segments woven into the game's campaign and quests.” Developer Crimson Delight Games' RPG feels like Valve’s ideal adult Steam game: An NSFW title that only features “consensual sex acts between adult characters.” No nonconsensual material (“noncon”), no incest, and certainly no lolis.

Nonetheless, this didn’t protect Crimson Delight Games from limitations on its content. On Sept. 16th, an r/Games post said Tales of Legendary Lust: Aphrodisia was hit by changes to "post-launch NSFW content" guidelines for published Steam games. The post is based off a post-launch announcement shared by Crimson Delight Games on the 16th, noting the studio’s issues with updating ToLL:A with new NSFW material.

“We had plans to add a few more lewd scenes to the base game while working on the DLC, but Valve doesn't allow post-launch NSFW content for an app that's already been through their review process and has released on the store,” Crimson Delight Games wrote. “There is nothing we can do about this — it's their rule, and breaking it would result in the game being removed from Steam. So please take that into consideration when asking for more lewd content for the base game.”

In a thread on ToLL:A’s Community Hub, Crimson Delight Games clarified that new lewd scenes for the adult game "will be included in the DLC as we complete work on them and fold them into the story," but this DLC update "might need to undergo review before release, due to NSFW content." The studio cited "the payment processor crackdown" causing changes to Steam's adult games approach, resulting in a "stricter approval process on Steam now."

“We are not allowed to add NSFW content to the base game... all post-launch adult content has to go through the DLC. We were told that during the review process from an official Valve reviewer who approved our game build,” Crimson Delight Games wrote in the thread. “I don't think the rules used to be this strict before, but since the whole payment processor situation went down everyone's been getting hit by it pretty hard.”

In August, Heavy Hearts’ Dammitbird said his adult game was denied entry into Steam Early Access because Valve is "unable to support the Early Access model of development for a game with mature themes.” Debate has since emerged around whether Heavy Hearts stumbled onto a new policy, a pre-existing one, or a weakly imposed limitation recently introduced. Assuming ToLL:A and Heavy Hearts represent maximal protection for Steam in the wake of payment processor censorship, the following may be a future path forward that all Adult Only Steam games face:

If this pathway becomes more commonplace on Steam, then adult game developers should stock up on Ibuprofen. The headaches will be immense. NSFW creators will have to hold onto their products until a 1.0 release or switch to an episodic model, relying on Patreon or SubscribeStar to stay afloat until they’re ready for content review with Steam (if Patreon or SubscribeStar will keep them afloat, that is). Even after release, attempts to offer additional adult content will trigger the post-launch DLC review process, which could end badly for an adult developer — either by delaying content updates as Steam reviews DLC, or forcing censorship if Valve rejects certain new additions planned for a game. Regardless, these increased restrictions and regulations on adult games turn NSFW developers into second-class creators, limiting and discriminating against their material compared to SFW games on Steam.

Granted, it’s worth noting that we don’t truly know what Steam has planned yet. Steam itself might not even know. The Early Access issue may come down to individual Steam employees’ discretion, or specific content triggered during Steam’s mature content review. As mentioned above, we still see several new and upcoming “Adult Only” titles admitted to Steam Early Access. 18+ title Heroes Saga publicly gained Early Access classification on Sept. 1st, as did NSFW VN B.E.S.T. 2 on Aug. 29th. Witch Potions - Craft of Lust also earned its Steam Early Access classification as recently as Sept. 14th.

In other words, ToLL:A’s experience may be a warning sign, not a representation of the future. We only have one data point from one developer. Some adult devs may receive confirmation from Steam to push new NSFW content updates through without going through DLC review. Others may try to do so without Valve’s blessing to mixed results. And more still may be told the exact same DLC guidelines as ToLL:A. Inconsistent communication and contradictory experiences are pretty standard when trying to publish a game on Steam.

To get a better understanding of Steam’s content moderation process around adult content, I spoke to an anonymous adult game developer who previously went through Steam’s review process for their “Adult Only” game. That developer spoke of Steam’s “Mature Content Survey” and said “incest isn't allowed anymore” nor “noncon as well.“

“Regarding incest / noncon, it’s confirmed by Valve. There's a ‘Mature Content Survey’ they make you take when going through the approval process for a game,” the anonymous developer told me. “And it specifically mentions they'll refuse to ship games with underaged characters, and games in high school settings. NSFW games, obviously. SFW ones don't have those restrictions.”

While the survey itself is nothing new, and in fact has been public knowledge for quite some time, consumers may be unfamiliar with the specific wording of the Mature Content Survey — including clarifications about what content is not allowed on Steam. The anonymous game developer sent over a copy of the Mature Content Survey, which they filled out around the beginning of August. Their title was submitted for Steam Early Access but denied. According to them, the Mature Content Survey is required for submitting a Steam storefront page for DLCs as well, meaning any adult developers forced to add post-launch NSFW content via DLC will have to go through the survey again.

“I'm not sure whether Valve will start checking DLC builds now (they haven't in the past AFAIK),” the developer said. “Guess we'll see.”

I’ve included individual images of the Mature Content Survey below, along with analysis.

The Mature Content Survey opens with a standard disclaimer, noting that developers “must disclose all the adult content you’ve uploaded in your builds, even if it’s not accessible or presented in your app.” Note that Steam takes this criteria very seriously; Valve originally pulled MangaGamer’s release of Bokuten—Why I Became An Angel over an inaccessible adult scene accidentally included in the game’s depot files. Valve claimed the scene featured “adult content with underage characters,” which resulted in a fiery public disagreement over the age of the character in question.

Steam asks many, many questions about content that may attract payment processor ire. Is there sexual violence, such as “rape” or “abuse?” Is there anything suggesting a minor might be involved in “sexual activity” or appear in a “sexual context?” Is there anything depicting underage characters “in sexually arousing poses?” You’ll want to keep this part in mind as we advance further through the survey.

There are also questions about whether genitals are seen, whether there is "explicit or graphic” sexual content, and if “favorable speech about illicit drug use” occurs.

Keep in mind that the Mature Content Survey isn’t just about adult content. Note there are references to “extremism” and “social themes” as well, including “references to abortion” and whether content includes “disparaging or hateful messages directed at certain population groups.” Developers also have to clarify if their game involves “glorification, denial, or gross trivialization of the Holocaust or other events of genocide.”

The Mature Content Survey also has pretty standard questions for categorizing games on Steam. Does your content depict mature content? Does it depict nudity? Sexual content? Is it frequent?

As for the “Adult Only Sexual Content” criteria, Steam provides various “common reasons we’ve refused to ship games.” The storefront notes that it must “adapt as content comes in,” so rejection for unspecified adult content restrictions is always a risk when working with Steam, even if you cross your lewd t’s and dot your suggestive i’s.

When it comes to verifying characters’ ages, Steam will “look at how characters in your adult content are visually represented, especially in the case where you have no narrative, or ages aren’t clear.” The storefront insists that if a “reasonable person” would believe your characters are minors, Steam “won’t ship your game.” As for “non-explicit sexual themes involving minors,” Valve relies heavily on context as well to “determine if we’re willing to ship” one’s game. This should all sound familiar, as it mirrors Patreon’s relationship with lolicon content (which has changed over the years).

Speaking of which, Steam outright bans depictions of minors in adult content, and it has a relatively wide criteria for what that means. This is because Valve stresses that a minor isn’t simply defined by a “narrative,” but also a “setting.” A character can be minor-coded, or “minor-presenting,” to steal a phrase from itch.io. Therefore, if you want to create adult work with “9000 year old vampires attending high school,” Steam won’t ship it. Same with “high school students who look like adults.” In fictional adult content, Valve has to determine whether your characters are quasi-minors in order to decide whether to allow or deny your adult material on the storefront.

This obviously poses significant issues for hentai games that want to reach Steam, and it’s likely why so many adult anime games rely on off-site 18+ patches. Hentai title Koikatsu Party, for example, features characters that look like adults, and so the game is allowed to remain on the storefront — Koikatsu’s Steam storefront page even notes “all characters appearing in this game are over the age of 18.” However, Koikatsu’s story mode takes place in a school setting, which is likely why Koikatsu Party’s Steam release does not include the story mode at all. Customers require an off-site patch to restore this part of the game.

Again, there’s also the question of whether a game is or isn’t minor-coded. Remember these aforementioned Mature Content Survey statements?

It seems likely to me that developers and publishers — especially those working in localization for Japanese titles — may find themselves at risk if their ecchi or adult games are deemed to depict “minors in sexually arousing poses, including where clothed.” Remember, Valve is forced to make subjective decisions about which characters are or are not minors. I could see this impacting non-adult games with pantyshots of anime characters in school settings, even if the narrative implies said female character is 18 or older. In an era where payment processor censorship is increasing, I’m also concerned about whether adult and ecchi games that take place in “academy” settings for adult characters will be dinged by Steam in the end because of Valve’s criteria on “setting,” not “narrative” alone.

Per the anonymous adult developer "underaged content with sexualized minors" is not a new ban from Steam. Colloquially, it’s long been considered a no-go for Valve. Although I expect the storefront to become stricter on “minor-presenting” characters as time goes on, and I predict the Mature Content Survey will grow in its prohibitive criteria listings for Adult Only games.

Payment processor censorship isn’t stopping, nor are government attempts to curtail speech. Degrees of Lewdity was softbanned by SubscribeStar recently, with developer Vrelnir directly pointing to “recent troubles regarding internet privacy and freedom, in the U.K. in particular, with governments restricting access to adult content.” Anxiety continues to mount over Texas’ SB 20, while Michigan is taking a stab at a pornography ban that would even target ASMR.

Hell, while writing this article, I reported on HobbyLink Japan’s “changes in our operations,” resulting in “the decision to remove all adult-oriented items from our website.” This led to the removal of 18+ anime figures from the site, and fans seemingly pointed the finger at payment processors. Then yet again, during the second pass on this article, I learned that Hololive can no longer accept PayPal on its official store. I’m concerned VTubers could face payment processor censorship next, given adult content featuring “cat ears” and various other “fantasy” elements were reportedly being targeted by MasterCard and Visa. Granted, Hololive would be a particularly strange target for censorship, given the agency does not work with adult content in any shape or form.

Valve is clearly forced to walk a tightrope. The company seems like it is trying its best to protect itself from further punitive measures by MasterCard, banks, and PayPal, all while trying to empower developers to host as much adult content as feasible. Where will the future lead for adult devs caught in the middle? Confusion, conflicting information, and more limitations, most likely. And zero adult games with 9,000-year-old vampire women finishing high school. That too.

Ana Valens is currently working as an independent journalist covering online censorship of video games and anime. You can help support her work by donating to her Ko-fi.