News Article

Feature: Lifting the Curtain on Game Ratings and the Headache of Worldwide Releases

Posted by Thomas Whitehead

Developers and publishers give us the details

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.

North America

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.

From the web

User Comments (71)



MAB said:

Yeah, the crew behind Unepic apparently don't want to pay for the Australian rating so that's why it hasn't arrived in our eShop... I would rather trade the crappy NES & SNES VC for more Aussie eShop indie support



AlexSora89 said:

Very informative. I'm gonna give it another read - it's awfully nice to finally understand what lurks behind the delays in European release dates.



Nintenjoe64 said:

Thank god for rating systems! Without the sterling work that these people do, the online components of mature rated games would all be filled with pre-pubescent voices shrieking deafeningly and playing horrible music up close to their mics.



Kohaku said:

Remove the region lock and there are no problems with the ratings anymore.



jangonov said:

Kudos to Thomas Whitehead on an incredible article. Things writtten this well, with this much research put into it, and that much thought is why I've been with this site so long.



Xilef said:

Very interesting article. It's a shame it has to be this way with none ESRB teretories.




So is ESRB free for downloads only or free for all games? I gather this is a recent development as well. If it's free for all how is it funded?

The UK had something before PEGI was introduced as well, but I can't remember what that was right now. I wonder how that compared?

This article really paints PEGI in a very archaic light. Which is a downright travesty considering what it's here for. I wonder what other business model they could use though? A subscription basis depending on your developer size? Or estimated releases per year? Having to pay for the same game but just on a different platform it also ridiculous.



StarDust4Ever said:

@Nintenjoe64 To bad the "prepubescent voices" thing is already happening, you know, because dumb parents basically ignore the ratings on the boxes. I was in a Game-X-Change the other day; some woman with three or four little boys running around in the store bought a stack of used Xbox titles. The clerk said "these games are rated M and may not be appropriate", she replied "oh I don't care what they play" and checked out.



LunaticPandora said:

I would still like to know why giant yellow USK stickers need to be printed on any collector's editions boxes but not standard cases, and in most cases that logo is also placed on the case that comes with the collector's edition, taking up more space than it should and ruining the box. I never understood the reason for this.



LittleFuryThing said:


So you discussed the issue of releasing (or not releasing, in some cases) with some of the game devs/publishers, but is there any chance you could ask for an interview with PEGI and OFLC why they feel their practices are - apparently - more appropriate than ESRB?

It would be interesting to read their perspective on why the process is designed to be more difficult and why they have to abide by it.
Frustrating, as it doesn't seem to offer any favours for us EU and AUS gamers.

Tah, very much.



banacheck said:

Thay should be greatful this isn't like the Board of Film Classification in the times of the infamous Mary Whitehouse.



Genesaur said:

Most interesting. I guess I'd always just assumed that the ESRB was a pain for developers; clearly, that is not the case, and I'm glad to have learned that.



Damo said:

@ferthepoet Region locking actually has nothing to do with it. Even region free systems like the PS3 are still subject to age ratings. These companies still have to pay for ratings, even if people choose to import from another region (which of course then has the negative effect of putting publishers off releasing games in certain territories).



Sinister said:

Well the ESRB ratings are easier to get but they are also automated. Noone is actully testing the game. I much more prefere for a game to be tested by an individual instead of relying on the information a developer provides.

You can bitch about the USK all you wnat but they do it right. They get the game, they play the game and they rate the game.



C-Olimar said:

I know it's hard, I just get jealous when yanks get to play cool games like ATV and I don't! Having said that, I do think it's better for a publisher to release a game when it's ready in America than delay it to coincide with the European release.



FritzFrapp said:

@ROBLOGNICK said "So is ESRB free for downloads only or free for all games? I gather this is a recent development as well. If it's free for all how is it funded?"
It's the fast-track download service that's free only. There are fees for retail games, and if I recall, lower fees for cheaper games. It's a nonprofit organisation (NPO). I don't know how they finance the fast-track download service. We covered many NPOs in my time on The Economist, but that's about the limit of my knowledge of the ESRB.

"The UK had something before PEGI was introduced as well, but I can't remember what that was right now. I wonder how that compared?"
The British Board of Film Classification – PEGI are a lot stricter, I can tell you that.




@Sinister The ESRB test the game after it's released. So they'll make you recall the game and either alter it or reproduce all the material to reflect the change of rating.



J-Manix98 said:

@C-Olimar I can't believe you just called us Yanks! That makes me laugh, but I our national Nintendo does have its problems too, such as; Lame pre-order bonuses, and terrible club Nintendo awards. Also the Not-as-good Game bundles... If you can think of any more tell meh!



Jaz007 said:

Nice article. It's good to see the ESRB makes things so easy. It also makes me wonder why Steam indies don't get ESRB ratings. It would be so nice. I don't see why not since it's easy.



unrandomsam said:

Nintendo wants family friendly. Something that is actually reviewed properly is inherently going to trustworthy and hence be more family friendly.

Yet again no numbers in the article.



unrandomsam said:

@Jaz007 Why ? No point in having it at all if it is not tested independently. Imagine if films could do that put what they like and then change it later it defeats the whole point.



MadAdam81 said:

Maybe it's time for us Aussies as well as all the Europeans to lobby our governments to change to an ESRB system. It's crazy that for a small Indy Australian dev team to not be able to afford to release a game in their own.region.
Is Australia like Europe in that each system release needs its own classification review?



MadAdam81 said:

@Damo for digital games, you would actually need to set up a console as an American console with a US credit card to buy from the US store.



ThomasBW84 said:

@unrandomsam Which numbers are you referring to? As I explained in the article, I made the decision not to publish the costs of the ratings services to ensure no NDAs or user agreements were breached, but instead gave some alternative descriptions to provide context of the fees. My interest is in discretion, and certainly not causing any unnecessary trouble for the interviewees, so that's why I took that approach.



FritzFrapp said:

Blue labels? Oh yeah, you must mean the ELSPA. The Entertainment and Leisure Software Publishers Association was a group set up by British publishers – they voluntarily rated stuff that was exempt from classification, for whatever reason, by the BBFC. Both superceded by PEGI.



C-Olimar said:

@JellySplat I think all 3 branches of Nintendo have their own problems. Better synergy between the three will lead to benefit for us all!



Kirk said:

The PEGI ones are so much easier to get at a glance.

There really shouldn't be a cost for rating your games though.



SaKo said:

I REALLY hate living in Australia...
We get to miss out on great games like Cave Story, Shantae: Risky's Revenge, Retro City Rampage, Nano Assault EX, Mighty Milkyway, 99bullets, etc. Plus the fact that the games cost 50% more... and the internet here is slow as heck so I can never join online games...



Chubblings said:

@StarDust4Ever Just the other day, I was in a game store, and there was a 7 year old kid with his mother, looking for PS3 games. One of the guys who worked at the game store knew that the kid was buying the game, and recommended God of War, and the mother and kid had no hesitation to buy it.



unrandomsam said:

@Damo It must be that they choose to as opposed to they have to otherwise Steam / Apple / Google wouldn't be able to just ignore that requirement completely. (Or it only legally applies to Retail games).



Usagi-san said:

As much as I'd like more awesome games in australia the ESRB Just sounds like a label printing service.
Have there been any notable games that needed to have their ratings updated recently?



Senario said:

Interesting, while I do agree with ESRB being generally free I wish that it was on a number system rather than using a vague term such as "Mature". It also would stop kids from looking at the box and saying "It's mature! get me this one" Because I'm fairly sure most kids wanted to be mature adults at some point in time. Although I guess it doesn't solve everybody's perception of E for everyone being "Only for kids", that is a silly distinction that people came up with for no good reason.

Basically, PEGI numbers = Better, ESRB freeness = Better. Combine the good parts and you got a better rating system.



Dave24 said:

PEGI is such nonsense it's painful - 18 is 18, adulthood in some (if not all) countries of EU, and yet they need to censor it for adults not to see adult content



Senario said:

@BenTheDemon Kinda, not really. Only from a monetary standpoint. The letter system of E, T, M ect is pretty bad imo compared to the color coded and numbered PEGI system.



deathlysneer said:

New Zealand IS NOT Australia. We have a completely different rating system! Games in NZ don't have to be classified unless they have been restricted in other countries. I wish publishers (and bloggers) would stop lumping NZ in with the stupid Australian market.



Manaphy2007 said:

so our rating system is the best? thats cool and all but the other countries should follow the usa rating system so the others will get games they want for their country



Manaphy2007 said:

@Senario i actually agree, m should be 18+, we should follow the EU rating system along with the freeness and making sure that only the adults get the game though that may not stop kids from finding a loophole like pretending its for their adult relatives and gives the game to these "mature" FPS-nerds



unrandomsam said:

@Senario I would have loved something like Madworld at about age say 11-14. It is not a mature game though its incredibly immature.



JCnator said:

Didn't PEGI's Simon Little unveiled International Age Rating Coalition (IARC) at last year’s London Games Conference? They said that the procedures of getting the games rated will be similar to ESRB and is due to be rolled out early this year. Major industry players including Nintendo are interested in IARC. While this seems to be important for the gaming community, it somehow went unnoticed by the network.

Source link:



Squidzilla said:

Brilliant and informative article here. Makes me want to dig up ''This Film Is Not Yet Rated'' for a rewatch!



ThomasBW84 said:

@JCnator Interesting stuff, it'll be interesting to see how widely it's adopted; I get the sense cogs always turn slower in these things than the agencies / bodies themselves would like to pretend. I think there's plenty of debate to be had between how much control ratings agencies and devs should have, respectively. Certainly there are talks and rumours about new systems coming in, seeing whether they're adopted and come into force will be the key.

We shall see! It's be great to have a worldwide system, regardless, so that regional disparity could be limited to localising languages, arrangements with platform holders etc, with ratings one less hurdle.



Razzle said:

Typical Australian approach - bog everyone down in red tape so a few public servants with can justify their existence. Wrap the kids in cotton wool so much they suffocate! This is a terrible approach and makes me feel for Indie developers especially. Plus, I am an Australian gamer and I really want to play these games!



losingtheplot said:

great article. love the COB here. though i would not want the esrb's hockey mum stance on sexuality all around the world thanks



TingLz said:

@Jaz007 Probably because the big 3 (Nintendo, Sony and Microsoft) all require ratings while Steam does not



Jaz007 said:

@Unca_Lz Makes sense, but if it's free and takes 10 minutes, then I don't see how it wouldn't be worth it. That's what puzzles me here. (Unless there's I misunderstand about it being free)



Yoshi said:

@Manaphy2007 Don't forget that ESRB has an AO rating, standing for Adults Only (18+). Its just that almost every developer and publisher frowns upon games that have that rating.



StarDust4Ever said:

@brewsky No, it's not the developers that don't want to publish AO games. They are perfectly legal, however none of the console manufacturers Nintendo, Sony, MS, Apple, Google, Steam, noone will license AO games, leaving only PC gamers in the loop. Secondly, decency laws would require the games to be sold in those shady "back rooms" or in novelty shops, where the clerk hands you the goods in a brown bag. This leaves out the vast majority of retailers who would refuse to stock such games even if perfectly legal, for fear of public backlash. What you're left with is a very small niche market so games will have to be developed cheaply and sold at high cost. Unlicensed "adult" games were developed for Atari and NES, and the companies involved all went bankrupt, creating what is essentially high priced novelty items for collectors. And if a person is that desparate, there's plenty of crude flash games freely available in places like newgrounds.



Wowfunhappy said:

Hey, so while I appreciate NintendoLife not wanting to put developers in a tough position, have any non-employees done any research into the matter that they could independently share? I haven't found much myself and, unfortunately, I feel like I'm still missing a lot of the picture here without hard numbers.



ThomasBW84 said:

@Sweet16 In what way? In terms of the quotes from developers about rating for the country, that's their experience, even if it's obviously disappointing.



Seren77 said:

Nintendo needs to subsidise the costs and help people get this done. If they are going to sell the console in these countries they need to make sure they are getting all the games too



Cengoku said:

Do as my brother and me did. We're living in Europe and we don't buy anymore consoles and games from here. My brother has the US versions of Wii u and 3ds. I own the jap version of those. I don't care anymore about going to stores here



unrandomsam said:

@Cengoku I would do that were it not for the massive risk of ending up with loads of digital content on the device and no way to get it repaired.



123akis said:

why do regions need different age rating companies anyway!? we are ALL humans!! ALL regions should JUST use ESRB



Sweet16 said:

@ThomasBW84 A big problem is the conflation of Australia and New Zealand, which are completely separate countries with separate ratings systems. In addition, the body which was formerly the OFLC is the Australian Classification Board. I have no idea what COB is supposed to be? The article also demonstrates a lack of understanding for why the American system can not simply be imported over.



ThomasBW84 said:

@Sweet16 COB was an abbreviation that pinged around in the interviews, admittedly it seems to be an informal term for the Classification Board in Australia, so point very much taken. As for Australia and New Zealand, our interviewees only go through one process for the region, so I took their lead on that.

I proposed various ideas for how things could move forward outside of North America, and I'd be surprised if ESRB stays 'free' for downloads forever, for example. It seems that was a gesture to cater to a smaller market, which may evolve. As another commenter has pointed out, there are attempts (backed up by comments from one of our interviewees made as an aside to me) to unify ratings more and make them easier to obtain in Europe and beyond. Hopefully that'll come through, but we'll see.

On the Australia / New Zealand connection made, I'll have another look into that, and certainly some of those I spoke to referred to them together, with one process for both. As I say, I'll look again.



Senario said:

@123akis No, mature is a very vague term and much less information is actually conveyed by their ratings on the box. PEGI's system does the numbering better but in terms of monetary cost, ESRB does it better. If there was a way to merge the two systems and take the best of each then we would have a system that would work worldwide. Also different countries have different definitions of appropriate content. In many countries around the world if there is too much violence they can cry foul. In America if you drop the tiniest hint of sexuality or anything close to that theme then they get really outraged with no good reason. Or even just a tiny bit of skin somebody deems too much. Because that is certainly more dangerous than violence (sarcasm).



unrandomsam said:

@ThomasBW84 Why no numbers ? (Surely the way to get them would to be just ask as if you were going to make a game). It is very different if it is £100 to if it is £10000.



HawkeyeWii said:

Wow didn't know the other countries had such a tough time. I'm glad I live in the USA. The others seem like a pain for publishers.

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