Age ratings in video games — an international practice — a column by REVERA

The topic of age ratings has been a hotly debated issue in the Russian gaming industry over the past year due to markings proposed by the RVIA and APRIORI associations. Considering that one of them may well be mandated for all gaming projects distributed in Russia, it's high time to examine international practices. In her column for App2Top, Svetlana Gordey, a leading lawyer from REVERA, detailed the history and types of these markings.

Svetlana Gordey

Different regions have their own age rating systems, typically considering aspects such as violence, sexual content, drug use, and foul language.

A Bit of History

Age ratings in the video game industry emerged in response to societal concerns about game content and its impact on children and teenagers. The history of their origin and development has several key stages.

In the 1980s, when video games began gaining popularity, there was no unified age rating system. However, with the increase in games featuring violence and other controversial elements, the first attempts at regulation emerged. For instance, in 1982, Atari introduced its game labeling system.
In 1994, the Entertainment Software Rating Board (ESRB) was established in the U.S. in response to public debates and congressional hearings about violence in video games, such as Mortal Kombat and Night Trap.
In 2003, the Pan European Game Information (PEGI) system was launched in Europe, unifying various national rating systems into a single structure.

Over time, systems like ESRB and PEGI have become international standards. Many countries have adapted these systems or created their own based on them. For instance, in Australia, the Australian Classification Board (ACB) is in place, and in Japan, the Computer Entertainment Rating Organization (CERO).

In most countries with their age ratings, they are mandatory (in addition, many platforms separately require a video game age rating), regardless of their distribution (on physical media or digital platforms).

Failure to comply with these requirements in a country where the rating is mandatory or on a platform where this requirement exists can have specific consequences for publishers/developers. For example, the game won't be allowed to be sold on that platform; if there is such a rule in the country, the absence of a rating could lead to a sales ban or other legal consequences.

Pan European Game Information (PEGI)

PEGI is an age classification system for video games, created to protect minors from content that may be inappropriate for them. PEGI has been in operation since 2003 and applies to most European countries. Its primary goal is to provide parents with information about video game content so they can make informed decisions about their children's use of video games.

PEGI uses age categories and content descriptors that indicate the presence of violence, drugs, gambling, or sexual content in a game. For example, an icon with a fist indicates violence, while a syringe icon indicates the presence of drugs.

PEGI age categories:

3+ — suitable for all ages;
7+ — may contain scenes that could be frightening for young children;
12+ — may include moderate violence, language, or sexual innuendo;
16+ — may contain realistic violence, sexual activity, or drug use;
18+ — intended only for adults and may include scenes of intense violence or sexual content, drug use.

The PEGI system is recognized and supported by the governments of many European countries and is an important tool for regulating game content and protecting children from potentially harmful influences. However, specialized legislation exists in some countries.

PEGI regulation is based on a Code of Conduct and may include the following obligations for developers and publishers:

Developers and publishers are required to accurately display age ratings and content descriptors, or violations may result in the revocation of licensing to use PEGI logos and descriptors as well as other sanctions.

Video game advertising and marketing must correspond to the age rating of the game. For instance, games rated 18+ should not be advertised in places where children might see them.

Publishers must inform retailers of the requirement to comply with age restrictions when selling video games, which includes employee training and ensuring games are not sold to those under the required age.

Entertainment Software Rating Board (ESRB)

ESRB is an American age classification system for video games, providing information about game content. This system has been in operation since 1994 and is used in the United States, Canada, and Mexico. It covers all major gaming platforms and is part of the parental control tools offered by these platforms. ESRB ratings are also used in digital stores such as the PlayStation Store, Xbox Live, and Nintendo eShop.

ESRB also uses content descriptors that indicate the presence of such elements as violence, foul language, sexual content, drug use, and gambling in a game.

ESRB age categories:

EC (Early Childhood) — suitable for young children;
E (Everyone) — suitable for all ages;
E10+ (Everyone 10 and older) — suitable for ages 10 and older;
T (Teen) — suitable for ages 13 and older;
M (Mature) — suitable for ages 17 and older;
AO (Adults Only) — suitable only for adults.

Although ESRB ratings are not legally mandated, most major publishers and platforms adhere to this system. In some U.S. states, laws require that video games with certain ratings be sold only to adults. ESRB also collaborates with the Federal Trade Commission (FTC) to ensure adherence to advertising and marketing rules.

Developers and publishers seeking an ESRB rating must submit their games for evaluation, providing a detailed content description and sometimes video footage. ESRB analyzes the submitted material and assigns an appropriate rating. Violations of ESRB rules can result in fines, the revocation of ratings, and other sanctions.

Computer Entertainment Rating Organization (CERO)

CERO is a Japanese age rating system for video games. It has been in place since 2002 and applies to all major gaming platforms. This system provides information about video game content to help parents make informed decisions regarding their children's video game usage.

CERO contains content descriptors pointing to the presence of elements such as violence, foul language, sexual content, drug use, and gambling.

CERO age categories:

A (All Ages) — suitable for all ages;
B (Ages 12 and up) — suitable for ages 12 and older;
C (Ages 15 and up) — suitable for ages 15 and older;
D (Ages 17 and up) — suitable for ages 17 and older;
Z (Ages 18 and up) — suitable only for adults.

This system was created as a division of the Computer Entertainment Supplier’s Association (CESA) and became an officially recognized nonprofit organization in December 2003. While CERO is not legally mandatory, most publishers and platforms in Japan adhere to this system. Sometimes, games not meeting CERO standards can be banned from sale.

Developers and publishers seeking a CERO rating must submit their games for evaluation along with detailed content descriptions and video footage. CERO analyzes the submitted material and assigns the appropriate rating. Violations of CERO rules can lead to the revocation of ratings and other sanctions.

Online Game Age-Appropriateness Warning

Online Game Age-Appropriateness Warning is a Chinese system aimed at protecting minors from content unsuitable for them. It was established in 2020 with the participation of major gaming companies like Tencent and NetEase. It applies throughout China and covers major gaming platforms. The system is regulated by the China Audio-Video and Digital Publishing Association (CADPA).

The Chinese age system also uses content descriptors that indicate the presence of elements such as violence, foul language, sexual content, and gambling in a game.

Age categories in the Chinese rating system:

6+ — suitable for ages 6 and older;
12+ — suitable for ages 12 and older;
16+ — suitable for ages 16 and older.

The Chinese age system is based on government standards and regulated by legislation aimed at protecting minors from harmful content. Video games must undergo mandatory inspections and receive a corresponding age rating before release. Violations can result in fines and distribution bans. Failure to indicate age restrictions can also lead to fines or other sanctions.

Unterhaltungssoftware Selbstkontrolle (USK)

USK is the German age classification system for video games and other entertainment software. It was founded in 1994 and is applied throughout Germany. USK provides information about game content to assist consumers, especially parents, in making purchasing and usage decisions regarding video games. USK covers all major gaming platforms, including consoles, PCs, and mobile devices. It is also used in digital stores like the PlayStation Store, Xbox Live, and other platforms available in Germany.

USK uses content descriptors indicating the presence of elements such as violence, foul language, sexual content, and drug use in a game.

USK age categories:

0 — suitable for all ages;
6 — suitable for ages 6 and older;
12 — suitable for ages 12 and older;
16 — suitable for ages 16 and older;
18 — suitable only for adults ages 18 and older.

The USK system is regulated by German legislation, specifically the Youth Protection Act (Jugendschutzgesetz). According to this law, all video games distributed in Germany must undergo mandatory checks and receive an appropriate age rating from USK. Violating these requirements can lead to fines and sales bans on the product.

Video game developers and publishers are required to provide detailed descriptions of their game content to obtain an age rating. They must also display age restrictions on packaging, in digital stores, and on loading screens. Failure to meet these requirements can lead to license revocation and other sanctions.

Additionally, a new mandatory requirement for age ratings for video games on the Steam platform has been recently introduced in Germany. This requirement applies to both new games and previously published ones. Games without ratings will simply not be visible to German users.

The Process of Obtaining an Age Rating

Preparation of materials. The publisher gathers all necessary materials, including game descriptions, gameplay videos, and screenshots to be evaluated by the rating organization.
Application submission. The publisher submits their application to the appropriate rating organization.
Content evaluation. The rating organization analyzes the provided materials and assesses the game's content against established criteria.
Rating assignment. After evaluating the content, the video game is assigned the appropriate age rating, which must be indicated on packaging and marketing materials.

Costs and Timeline for Obtaining a Rating

Cost. Typically, publishers must pay for the rating organization's services. For example, the cost of obtaining an ESRB rating can range from a few hundred to several thousand dollars, depending on the project's scale.

Timeline. The process of obtaining a rating can take several weeks to a few months. The time required depends on the complexity of the game and the workload of the rating organization. For instance, obtaining a PEGI rating usually takes about 4-6 weeks.

Impact of Age Ratings on Game Development

Game developers often face the need to adapt content depending on the target market. For example, in the U.S., the ESRB system might require changes to scenes involving violence or sexual content to achieve a lower rating, thus broadening the game's audience. In Japan, the CERO system might be stricter regarding depictions of blood and violence, requiring developers to make changes to graphics and storylines.

The most frequent age system restrictions include:

limitations on the level and realism of violence;
bans or restrictions on sexual scenes and nudity;
limitations on the depiction of drug and alcohol use;
limitations on the use of foul language.

These requirements compel developers to carefully plan every aspect of a game to meet set standards and avoid sales bans in certain countries.