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Rated and Willing: Where Game Rating Boards Differ

December 15, 2005 Article Start Page 1 of 2 Next

[This article was originally written for the December 2005 issue of Game Developer magazine, the leading publication for professional game developers. Worldwide paper-based subscriptions for Game Developer are currently available, and digital subscriptions to the magazine, offering six months and a year's subscriptions alongside access to back issues for a reduced rate are also available.]

The recent controversy over the Hot Coffee mod for Rockstar's Grand Theft Auto: San Andreas, and its subsequent temporary re-rating by the ESRB from M (mature) to AO (adults only) has only intensified the focus on how video games are rated in the U.S. But in the British Isles, as we'll discover, game raters scratched their heads and wondered what all the fuss was about. This fact alone showcases the cultural and procedural game ratings system differences among different territories of the world.

We investigated and tried to compare the video game rating systems of four countries—the U.S., the U.K., Germany, and Australia. Each territory deals with games in a slightly different way, both in terms of how they are screened and how the government or voluntary bodies combine to allow the rating of titles, making for some fascinating comparison points. There's no empirical right or wrong when it comes to game rating—just the seldom-raised opportunity to look at multiple data points, and see how different territories hope to rate and compare vastly differing gameplay experiences for countries and people that are culturally different.

Full Disclosure, U.S.A.

Note: The statistics represent the ratings of games as they appeared on the shelf. Percentages based on 1,036 games rated in 2004.

The New York City-based Entertainment Software Rating Board (ESRB), a self-regulatory body established by the Entertainment Software Association trade organization in 1994, issues a rating to more than 1,000 games each year, a formidable task to be sure. That's practically every video game released to retail in the U.S. minus a few sold strictly online. Because of this volume, and the fact that games can sometimes take tens of hours to beat, the ESRB doesn't attempt to play the games all the way through in order to determine their content.

ESRB, United


New York

Entertainment Software Association (the ESA established the ESRB in 1994)

eC (early childhood)
E (everyone)
E10+ (everyone
10 and older)
T (teen)
M (mature/over 17)
AO (adults only/over 18)


“We depend on full disclosure of all pertinent content by the games' publishers,” says Patricia Vance, the ESRB's president, “and that's done through an extensive written questionnaire that documents everything that's relevant to our rating system.”

“Pertinent content” isn't the easiest concept to get one's head around, but it can mean, for example, not only the degree of violence of an act but also how much control the player has over that violence. In other words, after shooting a character, can the player continue to shoot that person after he or she is dead? And what is the effect if the player continues to shoot? Such details, which the ESRB says are totally pertinent to the overall intensity of the experience, are covered by the organization's lengthy questionnaire.

“We are actually quite specific about what we mean by ‘pertinent content' in our submission materials,” Vance notes. “Even if you were to interpret ‘pertinent' differently than we do, it would be hard to misinterpret it when you're filling out the submission forms. We also include information about how to review content and how to prepare it for submission. If publishers still have questions, there's contact information on our web site to reach the people in our ratings department with whom they're probably already familiar.”

In addition to the questionnaires, the ESRB expects to receive lyric sheets and highlighted scripts, if appropriate, along with videos that give a good idea of the game's context, story line, objectives, mission, options, typical gameplay, and especially, the most extreme violence, language, suggestiveness, and sexual content.

While Hollywood raters have the luxury of viewing completed movies, the ESRB does its job while the developers continue to remove bugs, link missions, and spiff up the final product. So, if the board believes it needs more information about a game, it will sometimes request a build of the title in its current state so that its staff can further evaluate the game in question.

Once the submission is deemed complete, the ESRB draws from its pool of part-time, independent adult raters who have no other ties to the industry but are willing to work two or three hours per week viewing content. Based on the feedback of at least three raters—but sometimes as many as nine—the ESRB looks for a consensus upon which to base its final rating.

Critics point out that it would be easy for publishers to fudge their submissions, perhaps leaving out references to violence in order to earn a less severe rating. But the ESRB holds firm (with consequences) that there's no incentive whatsoever to such shenanigans. If offensive portions of a game are discovered after it ships, the ESRB requires publishers to have the game re-rated, re-stickered, possibly recalled, with all advertising changed appropriately.

“It's extremely costly for a company to do that,” Vance notes. “Not only are the corrective actions expensive, but there may also be penalties and fines associated with nondisclosure.”

The ESRB has modified those ratings over the years, adding descriptors to better help consumers understand the rating system, and making the ratings and descriptors more prominent on the game boxes. Most recently, a new rating—E 10+, for everyone 10 and older—was added “because we felt that consumers, particularly the under-14-year-olds, were demanding a new category for those in-between years. And there was plenty of product that met those requirements, meaning not suitable for age 6 but not yet at the T rating [for everyone 13 and older],” says Vance. “Our goal is to keep the system current.”

Vance acknowledges that the next generation of game consoles and more advanced technology will definitely change the face of the industry, thereby affecting the ratings system. “I certainly think the online environment is a challenging one for us,” she notes, “especially when gamers can generate their own content, say, through mods. That's an area where parents need to be more vigilant, and one that I'm not so sure we can do much about.”

Developers have queried the rating system on occasion, saying that there is a place for mature games, but that large retailers refuse to sell anything with an AO (for 18 years and older) rating. Vance, however, believes that what happens in the marketplace should not be blamed on the ESRB, refusing to let herself or the organization be held responsible for such outcomes.

“That's the marketplace making up its own mind, not us. We're just here to accurately label product. If retailers choose not to sell AO product for whatever reasons—because they don't think it will sell, or they don't think their customers want them to carry it, or it doesn't fit in with their family-friendly image—that's their decision. Not ours.”

Voluntary And Governmental, U.K.

Note: The games dealt with by the BBFC are games that have lost classification exemption in the U.K. and have been legally classified. Percentages based on all games rated from April 2003 to June 2005.

In 1993, one year before the birth of the ESRB, the U.K. 's Entertainment Leisure Software Publishers Association (ELSPA) and the Video Standards Council (VSC) created the ELSPA system, which makes it necessary for all ELSPA members to submit their games for ratings. Just as in the U.S., it's a voluntary system which is enforced by most video game retailers who won't sell unrated games.

ELSPA, United

URL and



BBFC Ratings


Laurie Hall is secretary-general of the VSC, the standards body that administers the ELSPA system and represents the country's game publishers as well as more than 10,000 retail outlets. Between 1994 and 2003, Hall and his team have rated well over 7,000 games.

As with the ESRB system, the VSC depends on “the help and guidance of the game publishers who answer a series of questions which then throws up an age rating,” says Hall. “So far, we haven't had any examples of abuse or anyone deliberately hiding things from us.”

The games that receive the most mature ratings—for ages 15 and up and for 18 and up—are examined by the VSC before those ratings are applied. “That's to make sure that the game has been rated correctly at that higher, more sensitive level,” Hall notes.

Unlike at the ESRB, the VSC uses professional raters who examine the games in detail using cheat codes provided by the publishers. Their typical workload is approximately 200 games annually.

“What they are looking for is to make sure that the game hasn't crossed the line from being in the voluntary category to the mandatory category where the game needs to be submitted to the British Board of Film Classification (BBFC),” explains Hall; or, as stated on VSC's web site ( “Before a game can be rated under the voluntary system, it must be established that the game is exempt from legal classification in the U.K.”

According to British law, games containing gross violence and/or sexual content need to be submitted to the BBFC, a government body, for legal age classification. Only two or three percent of the games published—so-called “extreme games”—receive this treatment. In fact, the ELSPA system was developed specifically to deal with the overwhelming majority of games that would otherwise have had no rating at all.

“The penalties are quite draconian for a game publisher or retailer getting it wrong and selling a game that should have gone to the BBFC but didn't,” Hall warns. “Under the law, the fine can be unlimited, plus up to six months in jail. And so, everyone tends to follow the rules. It tends to concentrate the mind.”

In 2001, the Interactive Software Federation of Europe (ISFE) met in Brussels to tackle the issue of the growing number of national rating systems. At the time, there were already four rating systems in Europe , and the ISFE feared that confusion would erupt if every country created its own system.

“You can imagine what a game box would look like if it needed to carry 10 or 15 different age ratings on it,” says Hall. The ISFE's solution was the Pan-European Game Information System (PEGI), a single video game rating system that is now administered by both the U.K. 's VSC and The Netherlands Institute for the Classification of Audiovisual Media. The number of countries using the system has grown from 16 to 20, with the notable exception of Germany.

“There had been a shooting in a school there and, just as in the U.S., a computer game was blamed,” explains Hall. “Legislation was passed that all video games in Germany had to be rated by their government, which is still the case.”

As with the ELSPA system, any game publisher requesting a 16+ or an 18+ rating must have its game examined before it gets rated. Games self-rated for ages 3, 7, and 12+ are examined retrospectively.

While the PEGI members agreed on how they would rate games, there will probably never be agreement on what is objectionable and what isn't in the various member countries. For instance, the U.K. seems particularly concerned about bad language, more so than on the continent, but sexual content gets just a middling reaction, which is still more than in the Scandinavian countries which are extremely liberal in that regard. But when it comes to violence, the U.K. and other southern European countries are fairly accepting of it in their games, whereas Scandinavia is much more restrictive. The solution has been the use of “descriptors” on packaging. If a game gets an age 16 rating because of language, a mother in the U.K. who sees the “language descriptor” might prevent her child from buying it, but a mother in France, who isn't particularly bothered by such language, may have no hesitations about buying it for her 12-year-old.

“The same sort of cultural differences popped up with the so-called Hot Coffee issue with GTA,” recalls Hall. “I know the scene depicting a sex act caused a great stir in America. Even Hillary Clinton got involved. But we looked at it and it seemed relatively trivial. Did we change the rating? No, because it was already rated 18 for violence, which is the highest it can go. Would we have raised it if we could? I think not; as I said, that sort of thing is considered mild over here.”

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