In recent weeks some headlines have been made by the ratings agencies and the related processes for getting eShop games from development studios and onto our Nintendo consoles. An early shot was fired by Renegade Kid in an interview with us late last year, in which co-founder Jools Watsham explained why, to this day, some of the studio's games are yet to come to Europe and Australia / New Zealand.
There are multiple age rating companies in Europe and Australia/New Zealand: PEGI, USK, and COB. Each company requires a substantial payment to review your game, an online questionnaire, and a DVD sent to them with gameplay footage for them to review. This may not sound like much, but it is for us when we need to focus on the development of our games and not dancing with the age rating companies.
The ESRB in North America is an entirely different proposition, being an almost instantaneous and free rating process, and offers quite a contrast. More download game publishers have come forward, notably Nicalis highlighting that the process isn't easy in Europe, though in that case some blame was also attached to Nintendo of Europe. Then we have smaller companies such as those behind Bike Rider DX2: Galaxy, Spicysoft, saying that an EU release will come after North America as it's reliant on sales in the latter region — all due to "much larger costs that come up with releasing a game in Europe".
We've decided to delve into the details of the ratings systems, and truly understand how they work and why some releases can be impacted and delayed. In the process we've spoken to six developers and publishers of varying sizes in order to get beyond the loose accusations and myths around publishing, and to get the perspectives of those that matter the most in these areas.
On this first page we'll outline the core facts of how the ratings processes work in multiple regions.
The ratings body for North America is ESRB, The Entertainment Software Rating Board. It's also typically praised by those we've spoken to, for the simple reason that it's quick, efficient and entirely free. UK-based publisher Ripstone — which has brought Knytt Underground to the Wii U eShop, with more on the way — provided us with the following neat summary of how it works.
By a large margin the ESRB is the easiest to work with. With them, the rating process is completely free, and requires us to simply complete one online form using their Automated Rating Tool (ART).
The ART provides us with an instant rating complete with any necessary descriptors.
The process is very simple and can be completed in 10 minutes at any stage of the development, this is extremely convenient for games that may be a little behind schedule (not something we'd know anything about, ahem!).
There's also no requirement to re-rate the game should you develop it for release on another platform, provided the content remains unchanged.
The only thing to bear in mind is that they will post-moderate the game, and if they find that the rating was mis-diagnosed they will ask for the rating or descriptor to be changed, which may lead to an update being required to the store data or the game itself, which is perfectly reasonable and encourages us to remain completely truthful!
In many senses it's a self-regulated approach, placing the responsibility on developers to get that initial questionnaire right, with the downside that any errors will rightly lead to some inconvenience if problems are highlighted in post-moderation. From the perspective of developers and publishers of all sizes, there's actually no issue with ESRB that we can gather, as you'd expect with such a quick, free process. For those on the smallest budgets, such as BLOK DROP U publisher RCMADIAX, it's unsurprisingly the first port of call — this HTML5 based game was released on 6th March in North America, with other regions still pending. It says it all that "the only expense with them is the cost of a stamp to mail in an application on company letterhead."
It wasn't always that way, as Brian Provinciano of Vblank Entertainment — Retro City Rampage — explains.
When I started with Retro City Rampage before this new system, I had to go through a long questionnaire about the content and create video clips of each occurrence of potentially pertinent material. It took several days due to the the game being an open world crime adventure; over a hundred clips in total. A non-violent puzzle game would've been much less work, of course. That's all changed now though and is no longer required, which is excellent.
What matters is how it works now, of course, and there's nothing but praise from those that we interviewed.
Now we're stepping into less happy territory, as suggested above, with a current topic around download games on the eShop stores often revolving around titles yet to arrive, or landing in the region later than in North America. While some retail games can take a long time to arrive — anything by Atlus, for example — that issue can be around localisation concerns, which include languages and so on. Naturally multiple considerations affect download developers too, but with a focus on ratings it becomes clear why small companies used to the ESRB processes cringe at the task of bringing their games to Europe.
There are two separate rating agencies in Europe. PEGI (Pan European Game Information) is most commonly known and covers most of Europe, such as the UK, France, Italy, Spain and others. Then we have USK (Unterhaltungssoftware Selbstkontrolle) which is for Germany alone. In the not-too-distant-past — 2012 — games in the UK also had to be rated by the British Board of Film Classification (BBFC), but that was abolished in favour of adopting PEGI.
To begin with PEGI, it is not free. We will not give specific prices in this feature in the interests of discretion — some (not all) details can be found online — but the figures required, while affordable for most businesses investing in bringing a project to market, can still be considered problematic for small companies with tight budgets. The price varies depending on the size of a download file, so anything below 250MB has a discounted rate, before there's a fairly sizeable leap for those above that file size. Even on the lower rate, a budget title (eg €1.99) would need to sell — perhaps — a couple of hundred copies to meet costs, while games of a larger size that perhaps have an eShop price of around £7.99 / €9.99 would, with loose ideas of royalties applied, perhaps need to still sell a similar volume or slightly more to break even. Naturally no developer releases a game in a region such as Europe aiming to sell just a few hundred copies, but it could still arguably be a fairly big chunk of sales that goes into that initial rating.
The process is also a challenge beyond simply paying. PEGI requires that, in addition to an online questionnaire, physical media containing the complete game needs to be sent to the agency. Some time can be saved in the relatively quick rating turnaround — assuming the content sails through the process — by paying upfront (a requirement) while completing the questionnaire, for example, but aside from the financial cost the need to provide physical media is consistently raised as a complaint. As these are download games, it's surprising to learn — from Manfred Linzner of Shin'en Multimedia — that PEGI requires "a feature-complete version of the game and additional video footage". Jools Watsham of Renegade Kid explains the difficulty from his perspective with current project Moon Chronicles.
I wanted to give PEGI another shot with Moon Chronicles, so I filled in the on-line form and hoped that their system had been improved a bit since Mutant Mudds was submitted to them. Nope. They require video footage to be mailed to them, and they need a final build of the game mailed to them. So, I have to wait until the game is completely finished before I can even send them the materials for their review.
Moving onto USK (Germany-only) there are certainly similarities. Once again the prices are not inconsiderable, though the 'basic' service is certainly lower than the PEGI equivalent for larger games — an expedited option brings the costs closer to parity. As a plus, while PEGI requires that each platform release (so common in the current day) has a rating paid for separately — admittedly at a lower cost — USK allows the same rating to be applied across multiple platforms without extra payments; this is a concession for downloads only, and not applicable to physical retail. With so many titles now potentially arriving on up to half a dozen platforms, this could save a lot of money in the German market.
The process of assessment seems to be a little simpler — Martijn Reuvers of Two Tribes says it's "a lot easier" from his perspective — and there seems to be some flexibility in terms of initially sending a completed game through FTP (online file transfer) to move the process along.
A smaller organisation than the multi-national PEGI, USK plays through games itself, so while a final build is still required accompanying video and footage isn't, saving developers time in putting together accompanying film. It's also been highlighted to us that Germany is a major market and contributor to sales in Europe as a whole, so is a necessary country to include.
Australia and New Zealand
It's common for a number of games not to arrive in Australia and New Zealand, and speaking to developers it becomes immediately apparent why that is the case.
As with Europe, rating through COB in this region — formerly OFLC and still mistakenly referred to with that abbreviation, something of which we've also been guilty — brings costs, which add an extra burden but also, tellingly, a questionable ROI (return of investment). A common theme to releasing games in Australia and New Zealand is that it's a process that can lead to a loss, as it's a small market for the eShop stores. The process, too, as outlined by Ripstone below, is far from accommodating.
My experience with the COB has been quite an eye opener, the technology available to them isn't on par with the rest of the world, but the staff there are always really helpful.
Their submission package includes a copy of the game, ready for installation on the most suitable medium, be-it DVD, or USB-stick, plus a gameplay video showing anything 'rateable' or potentially contentious, plus 30 mins typical gameplay footage, along with instructions and a completed application form.
Payment details are added to the application form so payment is only taken when the package arrives in Australia, and is taken before the 'review days' begin.
If anything is missing from the package then that element needs to be resent while the review goes on hold so it pays to ensure everything they may need is included in the delivery.
Martijn Reuvers of Two Tribes made a similar point when telling us the technology used in the process is from the "Stone Age". A lengthy 20 day wait also comes with a standard application, with a relatively pricey upgrade to expedite the process to five days. Both Reuvers and Manfred Linzner highlight that Nintendo of Europe offers some assistance with the COB process in the right circumstances, but the awkward process, communication issues and price combine with low sales to scare some away. Releasing games in the region has been described to us as something done for the fans, as making money in the territory is difficult.
On the second page we tackle the issues and topics raised by these systems in detail, considering why they're important for download developers / publishers and how the ratings processes can be improved.