Update: Valve has provided us with the following statement with regards to future free Steam key allocation:
"Steam keys have always been available for free to our partners to help them sell PC games at physical retail and on other digital stores. In return, we've asked that partners offer Steam customers a fair deal, similar to what they're offering on other stores. None of that is changing.
"But over the last few years, new features and additions to Steam have changed the way Steam keys were being used, for instance as a means for game-shaped objects to monetize on Steam through methods other than actually selling fun games to customers. Most notably, this meant farming Steam Trading Cards. We shared a lot of info about that issue, and our response to it, here.
"While our changes did impact the economics of trading card farming for new products coming to Steam, there are still a lot of games and game-shaped objects using Steam keys as a way to manipulate Steam systems. As a result, we're trying to look more closely at extreme examples of products on Steam that don't seem to be providing actual value as playable games-for instance, when a game has sold 100 units, has mostly negative reviews, but requests 500,000 Steam keys. We're not interested in supporting trading card farming or bot networks at the expense of being able to provide value and service for players.
"It's completely OK for partners to sell their games on other sites via Steam keys, and run discounts or bundles on other stores, and we'll continue granting free keys to help partners do those things. But it's not OK to negatively impact our customers by manipulating our store and features."
Steam games can be purchased two ways: through direct payment to Steam, from which Valve takes a cut, or through third parties which sell keys that unlock the game on Steam. To sell or give away keys outside of Steam, developers must first request a batch from Steam. Given the quantity of keys in the market—we once gave away five million Steam keys—Valve has clearly been generous with key requests in the past. Those days may be over.
In a leaked post from Steam's developer forum, Valve employee Sean Jenkins explains that key requests can be denied if Valve feels a game isn't earning its keep, though it isn't clear how new this policy is or isn't:
"If we are denying keys for normal size batches it's likely because your Steam sales don't reflect a need for as many keys as you're distributing, and you're probably asking for more keys because you're offering cheaper options off Steam and yet we are bearing the costs. So at some point we start deciding that the value you're bringing to Steam isn't worth the cost to us.
"For example, say you've sold a few thousand copies on Steam but have requested/activated 500K keys, then we are going to take a deeper look at your games, your sales, your costs, etc."
Valve will no longer automatically fullfill key requests from the developers to combat game sales outside of Steam. pic.twitter.com/Gp1TyivEeOAugust 17, 2017
It's premature to say that the policy represents a crackdown on third-party key sellers such as Humble Bundle and Green Man Gaming—it may only apply to extreme cases, such as a developer hypothetically flooding third-party stores with dirt cheap keys for a 30 GB game that has barely moved the needle on Steam, causing Valve to bear hosting costs without receiving rent.
Based on developer reactions, though, it does appear that this policy is new: Drift Stage developer Chase Pettit suggests it may be a reaction to an influx of Steam Direct games. But given the example of "500K keys," niche games may not be affected at all. Visual novel developer WinterWolves said on Twitter that they rarely need to request more than 10K keys.
One theoretical issue with the policy comes from crowdfunded games, which may need to request large key batches for backer rewards before having any sales on Steam at all. However, even after earning nearly $3M on Kickstarter, Wasteland 2 ended its crowdfunding campaign with only 61,290 backers—far fewer than the 500K example cited by Jenkins. Crowdfunding may be a non-issue, then, depending on how strictly Valve intends to moderate key distribution.
And given that Jenkins describes the process as investigatory—as in, an actual person at Valve assessing the situation—it seems doubtful that Valve will nix legitimate requests. Denying keys to the developers of crowdfunded games wouldn't be productive for Valve, and denying key requests for bundles would be hugely unpopular, at least for games with some popular support.
Still, it's unclear how strictly the policy will be applied, or what Valve's ultimate intentions are—whether this represents a minor increase in hands-on moderation of third-party sales, or a significant initiative to keep game sales on Steam. I've asked Valve for clarification on the policy, and will update this post if I hear back.