Yes, except for one tiny mistake - the old Games for Windows specification says that saved games for Vista go in the C:\Users\<Username>\Saved Games folder, NOT Application Data, and the new one doesn't have any requirement at all for that - you can put them wherever the heck you want!  If they're claiming it's because of the Microsoft logo specification, they couldn't be more wrong.

Besides, Demigod already violates Games for Windows guidelines by having a shortcut in the Start Menu.  So does Sins of a Solar Empire.  The proper implementation is for the only way to launch the game being digging through Program Files for the executable, or somehow magically guessing that you should run it from the Games Explorer.  Lord of the Rings Online is an example of this.

Actually, as a Windows dev myself, one of the biggest reasons why stuff is saved to this folder (often called the APP_DATA directory by my colleagues) is more likely due to permissions. This is true since XP, so it is less likely to do with "Games for Windows" policies and Vista.

In normal XP with multiple user accounts, it is default that applications do not have read/write permissions to almost any place, including its own directory. This is why you often hear instructions that such-and-such app must be installed as Adminstrator. The only place that by default allows read/write permissions is in the specially created APP_DATA directory for each application. If an application dev wishes to have R/W permissions elsewhere, then special setup/configs are needed at install time (see install wizards, NSIS, et al). This can be a big hassle to do for an installer. And it can clash with other security policies that may be in effect at  the time.

The only other location for an app to save its own files is %TEMP% which clearly is not suitable, and the "My Documents" folder, which is probably already heavily overused. Besides, My Documents usually shows up in most applications' File > Open, so for an application to save app specific files which do not really need user access (eg. logs, saved data, etc), APP_DATA is the usual place.

So, just for reference in XP (this is true for most all standard Windows apps):

C:\Documents and Settings - Windows installed default

<username> - in case of multiple accounts on the same PC

Local Settings - to force data to be local, as opposed to roaming user profiles in Windows

Application Data\IronClad - self-explanatory

In Vista, it is the same, except that they merely moved folders and names around.

I just wanted to explain this so that people have a better understanding (a likely reason) why IronClad did this - to improve compatibility across all Windows installations - and not because they decided it on a whim