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On 9 March 2026, PRS for Music announced that it had commenced legal proceedings in the UK against Valve Corporation, the operator of the Steam platform, alleging, according to PRS, that Valve had made use of PRS members’ musical works on Steam without the necessary permission. PRS said it issued proceedings on 4 March 2026 after seeking for many years to engage with Valve about licensing. At this stage, the public account is drawn principally from PRS’s own statement of 4 March 2026 and trade reporting rather than from any court documents or any judicial findings – at the time of writing this article, there are no court documents publicly available. This article should therefore be read as a cautious and tentative analysis of the case theory PRS has publicly advanced and not in any way as a definitive account of the precise claims, arguments in defence or likely outcome.

To understand the thrust of PRS’s argument, it would make sense to start with a description of PRS for Music’s role, if you aren’t already aware of it. PRS for Music is the UK collective management organisation that operates a blanket licensing model for musical works, granting licences to businesses and online services to publicly perform, stream or make music available to the public, and collecting and distributing royalties to its songwriter, composer and publisher members when their works are used, including when they are streamed or downloaded. More generally, UK collecting societies are commonly used where repeated public performance or online exploitation would be impractical to license on an individual transaction‑by‑transaction basis, while other rights may be cleared directly. PRS’s public narrative against Valve appears to fit that model - it is treating Valve as a commercial platform operator that, in PRS’s view, should hold an appropriate platform‑level licence. Whether that characterisation is legally and factually correct in this context is likely to be one of the questions the litigation would need to resolve.

PRS’s statement dated 9 March 2026 describes Steam as a “digital distribution platform”, that being the medium through which users can purchase game-related digital content and download games that contain music. On that framing, the target of the claim is not the initial creative decision to include music in a game, but the later act of making the finished product available to users via Steam. That said, the exact legal characterisation of Steam’s role, and the extent to which that role is said to engage any restricted act, will ultimately depend on the pleaded case and evidence.

The statutory provision PRS will likely be invoking is section 20 of the Copyright, Designs and Patents Act 1988, which treats “communication to the public by electronic transmission” as an act restricted by copyright and expressly includes “making available” so that members of the public may access a work from a place and at a time individually chosen by them. That statutory wording is public and fairly clear. What is less clear from publicly available material is exactly how PRS has sought to map Steam’s activities onto section 20, and exactly how Valve may answer that case. The theory would be that, when games containing a PRS member’s repertoire are distributed by download through Steam, Valve is itself making those works available to the public and therefore requires a PRS licence. That may prove to be the central legal issue, but at present it remains conjecture rather than an established conclusion.

A central element of PRS’s public positioning is the separation of different music rights. In many game projects, music will have been cleared during development through synchronisation arrangements and, where relevant, other permissions needed to embed the track in the game. PRS’s reported contention is that those upstream arrangements do not necessarily extend to the later act of making the game available to the public through a third-party platform in the UK, and that a separate section 20 analysis therefore arises at platform level. That could be a plausible way of framing the dispute, but it should be treated with care. The scope of any existing licences, the identity of the party whose acts are said to engage section 20, and the extent to which any relevant rights are administered collectively in the circumstances of a given work are all matters that may depend on contractual detail and evidence not presently in the public domain.

This also helps explain why PRS may be publicly focussing on Valve rather than on developers. PRS’s statement frames the issue at platform level, saying that Steam has never obtained a licence for the rights managed by PRS and emphasising the scale and longevity of the service. Some reporting also refers to PRS having reported licensing arrangements with other major games ecosystems, including Sony Interactive Entertainment and Microsoft, and this could present Valve as an outlier. Even so, those comparisons should be treated carefully unless and until the underlying arrangements are publicly verified in detail.

As to merit, the most that can responsibly be said on the public record is that PRS’s theory is not obviously inconsistent with the breadth of section 20, which is drafted in technology-neutral terms and is capable of applying to on-demand digital availability. Whether Steam’s conduct amounts to an act of communication to the public by Valve, whether any such act is covered by existing permissions, and how a court would treat the platform’s role in the overall chain of exploitation are all fact-sensitive questions that cannot be conclusively resolved from the press coverage alone.

There are, however, several issues that may be expected to feature in any defence or in the court’s analysis. The dispute is likely to be highly fact-sensitive, because Steam distributes software created by third parties and the contractual chain between composers, developers, publishers and distributors may matter considerably. A defendant might argue that relevant permissions were intended to cover distribution through mainstream storefronts, or that the legally significant act should be attributed elsewhere in the chain rather than to Steam itself. Questions of territoriality may also matter, because section 20 is a UK right and any claim may need to be tied to UK acts of communication to the public rather than to the platform’s global operations in the abstract. None of those points defeat PRS’s case on its face, but each illustrates why the public reporting cannot do more than indicate the broad outline of the dispute.

In practical terms, the dispute may become an important test of how the UK’s “making available” right applies to large-scale digital distribution of games containing music. The platform is not performing or communicating the music as a standalone product, the music is inseparable from a privately enjoyed software product and characterising distribution of a game as a “communication to the public” of musical works could be stretching section 20 beyond its intended scope. Further, where music is embedded within a game, is a player really accessing the music “at a time and place individually chosen by them” (as required by section 20), or is the music simply one component of a broader interactive experience that the player receives when they choose to play the game?

The statement put out by PRS suggests that they are aiming for a licence covering past and future use of PRS repertoire on Steam. Valve, if it contests the claim, may be expected to resist any suggestion that a further platform-level licence is required, particularly if it considers the relevant music already to have been cleared upstream or the legally relevant act to lie elsewhere. However the case develops, the commercial significance is obvious - if UK law requires platform operators to obtain separate authorisation in circumstances of this kind, that may affect licensing practice, pricing, platform-publisher allocation of risk and the wider economics of music use in games. Equally, if the claim fails or is narrowed, that too would clarify the boundaries of section 20 in this sector.

A further commercial question is where the economic burden would ultimately fall if Valve were required to make royalty payments at platform level. It does not follow automatically that any additional licensing cost would be passed directly to consumers, but that is one possible consequence. Depending on Valve’s commercial model and its arrangements with publishers, the cost might instead be absorbed in whole or in part by Valve, reflected in altered revenue-sharing terms, or it could be taken into account in the pricing of games. Over time, if a platform-level royalty became a settled cost of distribution, it could contribute to upward pressure on retail pricing, changes in discounting strategy, or a stronger preference for titles with simpler music-rights positions. Equally, competitive pressures may limit the extent to which any such cost can be passed through.

Finally, a note of caution on all of this. The strongest statements that can be made today are limited to what is publicly verifiable - PRS has announced proceedings and set out the background, they have not mentioned section 20 CDPA but the wording of their statement would seem to point in that direction. Whether PRS ultimately succeeds will depend on the pleaded facts, the evidence about Steam’s role, and the court’s approach to how section 20 applies to games distribution in the UK - matters that cannot be conclusively answered from press coverage alone.

Disclaimer: This article does not constitute legal advice and the issues covered are speculative and non-exhaustive. It is only intended to provide information of general interest about current legal issues. As all circumstances are different, you should not rely on the content of this general information and you should take specific professional advice before taking any action in relation to the information provided.