by Andy Robertson
There’s a simple answer for anyone confused or alarmed about the content they find in a video game: read the ratings on the box. Scratch beneath the surface, though, and it’s more complicated than that. We actually have several ratings systems at work in the UK, and their criteria all differ.
In the UK all boxed video-games must have a PEGI (Pan European Game Information) rating specifying who the content is appropriate for: 3+, 7+, 12+, 16+ or 18+-year-olds. Digital stores on game consoles voluntarily require a PEGI rating for games to be sold. Steam applies the PEGI rating if one exists, but doesn’t require one for a game to be listed.
Smartphone and tablet game ratings are defined by each platform holder. On Android developers rate their content as being for Everyone or requiring Low, Medium or High Maturity. On iOS developers rate their content as appropriate for different ages, 4+, 9+, 12+ and 17+. On Windows phone developers rate their content as being appropriate for 3+, 7+, 12+, 16+ or 18+ players.
For anyone buying boxed games for consoles, the PEGI system is the one that will apply. Since 2012 the Games Rating Authority has been the sole body responsible for rating video games in the UK, using the PEGI system. Previously this had been a mixed economy, with BBFC and PEGI ratings appearing on different games. Frankly, it was kind of a mess.
This division now recognises the different expertise and criteria required to rate video game, as opposed to video, content. The PEGI ratings are owned by ISFE, funded by game publishers and focus on the mechanics of what happens in the game, with less emphasis on context and setting.
UK Government legislation enforces PEGI ratings on the supply of a “video work” that is “contained on any disc magnetic tape or any other device capable of storing data electronically”. It is illegal to “supply” a game for “reward” or “business” to an individual who is under the stated 12, 16 or 18 age rating. The 3 and 7 ratings are advisory and not legally enforced.
It is illegal to “supply” a game for “reward” to an individual who is under the stated age rating. It is not illegal for a parent or third party to purchase a game for a child who is under the stated age.
These terms mean that it is not illegal for a parent or third party to purchase a game for a child who is under the stated age. They also don’t apply to downloadable apps and games although Xbox Marketplace, PlayStation Store and Nintendo eShop make PEGI ratings a requirement for the games they provide.
The PEGI process starts with the publishers completing a questionnaire to disclose all aspects of the game that may impact its rating, and provide video footage of these sections of the game. Failure to disclose full details can lead to a maximum fine of €500,000 - although no publisher has been penalised to date.
The cost of submission depends on the size of game. At the time of writing “standard” console games are €2100 for the first platform and then €1050 for each additional platform. This means that Skylanders Trap Team would have cost €8400 to get PEGI rated on its platforms Wii U, PlayStation 3, Wii, Nintendo 3DS, Xbox One, PlayStation 4, Xbox 360. “Casual” games that are less than 450MB cost €260 and “budget” games with development costs less than €200,000 are €155. This certainly helps reduce the barrier to developers when it comes to getting titles PEGI rated and released on consoles.
PEGI examiners then watch the video and play a proportion of the game to arrive at their assessment and the publishers are informed of the age rating details.
The publisher can appeal this provisional rating, as was the case for Disney Infinity 2.0: Marvel Super Heroes, which received a provisional rating of 12 that was downgraded to 7 after appeal. Gianni Zamo, Communications Officer at GRA, explained the process here: “The publisher filed a complaint against the initial decision to give Disney Infinity 2.0: Marvel Super Heroes a PEGI 12 rating. The Complaints Board, an ad hoc committee of independent experts, concluded after further examination that, on balance, the game could be contained at PEGI 7 due to the cartoonish context in which the gameplay unfolds.”
Whether the ratings are effective depends on what you expect them to achieve.
Zamo outlined how this process leads to refinement of the questionnaire. “Every time the Complaints Board, who handle on average 3 or 4 cases per year, overturns a decision, recommendations are made to the PEGI Experts Group, who will further investigate the precedent to determine what changes, if any, are necessary to the criteria in order to accommodate similar games in the future.”
Beyond the single age limit, the meat of the PEGI rating is in the detail. A set of content descriptors for Language, Drugs, Fear, Sex, Violence, Gambling and Discrimination on the back of the box outline why a game received a specific rating. The severity of these occurrences determines the age rating, taking violence as an example:
- PEGI 3+ games won’t have a violence descriptor but may contain “Tom and Jerry” slapstick violence if it is not considered disturbing.
- PEGI 7+ games flagged with a violence descriptor may include “non-realistic violence towards fantasy characters” or “implied violence”. (294 occurrences in 2013)
- PEGI 12+ will have the Violence descriptor to signpost “violence towards human like characters” but this must be non-realistic so that bodies don’t remain when killed. This may also include violent sports like boxing providing there is no blood. (262 occurrences in 2013)
- PEGI 16+ games are flagged for “violence towards human characters” who react to being shot as they would in real life. This will often include blood and bodies will remain once they are dead. (211 occurrences in 2013)
- PEGI 18+ games are flagged for including violence towards humans that may make you “wince” or your “stomach churn”. This includes gross depictions of heads, arms, and legs being removed by way of chain-saw or shotgun. It also includes sexual violence such as rape and mass killings of civilians. (149 occurrences in 2013)
These details are further fleshed out by the Additional Consumer Information provided by the GRA for each 12, 16 and 18 rated game. This goes into fine detail about particular occurrences and scenes that triggered the rating. For example, The Evil Within’s 18 rating for violence stated that “the player’s character is decapitated by a gruesome monster with a chainsaw”.
Doesn't really look like a game for 12+-year-olds, does it?
Whether the ratings are effective depends on what you expect them to achieve. Under current legislation PEGI isn’t intended to stop every under age child playing an inappropriate game -- although it does stop underaged consumers purchasing the games themselves at retail. Rather, as stated on the GRA website, “PEGI gives you, as a parent, the information to make a choice to allow your child to play these games.”
Rather than prohibition, the bigger shortfall for UK video-game ratings is ensuring parents know the resource is there and access it before making purchases, not just in terms of the top-line age limit but also the highly useful detailed information that sits behind it: content description and additional consumer information in particular.
One challenge here is that certain PEGI ratings sometimes seem counter-intuitive. Even understanding that they are about appropriateness rather than suitability (F1 2014’s 3+ rating isn’t suggesting it is for 3 year olds, for instance), other peculiarities arise from PEGI intentional blindness to context.
Violence against human characters will trigger the same rating regardless of whether those are innocent civilians or superhero villains.
Violence against human characters will trigger the same rating regardless of whether those are innocent civilians or superhero villains. Hence something like The Amazing Spider-Man is rated as 16+ when many younger players will have happily watched the 12A rated film. Ben 10 Omniverse, is another example: the PEGI 12+ rating suggests many of the U-rated show’s young fans shouldn’t play the game, but you’d be hard-pushed to find 12 and 13 year olds who’d be seen dead playing Ben 10.
The PEGI website and app, along with physical game boxes do a good job of communicating the age limit and content descriptors. But the Additional Consumer Information (ACI) that provides the GRA’s fullest account of the game’s content is only accessible via the GRA’s website and unlikely to be found by anyone Googling for information. A better place for these ACI details would be in the PEGI app itself.
To its credit the GRA has recently started providing this Additional Consumer Information via Twitter, and responds quickly to consumer questions. It’s this positive action that will make the biggest difference in getting word out about its informative library of information.
Ukie's Ask About Games advice site.
Additionally, the Ukie funded website AskAboutGames.com, which I edit, offers a place for parents to learn more about game ratings. It provides 2 minute video guides to recent games that highlight all the PEGI information within a broader context.
Overall, in my estimation, PEGI offers a consistent and transparent way to apply the legislation that controls video game distribution. Some will find these ratings too severe or disagree with the age a particular game has been given. Others will criticise the system for not being robust enough at stopping children playing older rated games.
While there is room for improvement at communicating the depth of information around these ratings to parents, PEGI works with current legislation to enforce a legal age-gate to purchase. More than that though, it provides a context-free yardstick for consumers to make informed decisions about which games are most appropriate for particular players. That, ultimately, is perhaps the most useful thing an age ratings system can offer.
Andy Robertson is a freelance family technology expert. He runs the Family Gamer TV YouTube channel and contributes to a range of national media on the topic of video-games and family.