Meeting the people of PEGI: talking age ratings, gambling, and why their famous voice only got €200
"We're not a group of corporate men in suits trying to stop everybody's fun."
Close your eyes and imagine a game trailer and tell me how it begins. Something happens at the very beginning before anything else - before you see anything of the game. There's a logo and a voice, and it's deep and posh and English. The words it says are iconic. "PEGI 18," you hear. Or maybe "PEGI 16" or "PEGI 12". It's such a well known phrase that when a man called Richard Wells popped up on TikTok to claim he was the one who said them - and then proved it by saying them - more than 20 million people watched. They left comments saying it gave them goosebumps and that those words represented their childhood, which is a bit worrying given the "18" part. But the overwhelming response proved without a shadow of a doubt that for millions of people, PEGI age ratings are ingrained in our collective gaming mind.
PEGI stands for the Pan-European Game Information age-rating system, and it's been the way we rate games in the UK and across most of Europe for more than a decade. The PEGI age-ratings have actually been around for longer - for 21 years - but it wasn't until 2012 they became the sole age-rating system for games in the UK. The BBFC - the British Board of Film Classification - rated games before that. We're very familiar with PEGI age-ratings as numbers on a box, then, and as a voice in our ears. But how much do we actually know about who's running it - the people there? In all of the years I've done this job, I've never met anyone from PEGI, I realise. To me, it's a faceless organisation, and a serious one - the health and safety department of the games industry.
That's why I'm caught off guard when two people approach me in a hotel lobby and would you believe it, they look completely normal. They're not wearing suits or fluorescent hi-vis vests but are instead casually dressed in red and black hoodies. "Bertie?" they ask, with an expectant smile. I'd arranged to meet PEGI people here but I've been standing here for 10 minutes, staring, with no idea it was them.
They are Ian Rice, the director general of the Games Rating Authority, and Craig Lapper, director of policy and communications. Rice has worked there nearly 14 years, and Lapper for four, though he spent a whopping 22 years at the BBFC beforehand, so the age-ratings business is etched into his bones. A clarification: the Games Rating Authority is PEGI, sort of. It's one of the two independent bodies that issues the PEGI ratings. The GRA issues the 12, 16 and 18 ratings, so the games we typically play, and a separate body in the Netherlands called Nicam handles the 3 and 7 ratings. Funnily enough, the PEGI ratings themselves are owned by the video games industry.
I'm disarmed by the informality of it all and by the informality of them. They're not what I expected and, apparently, it shows. "We're not a group of corporate men in suits in an office in London that are trying to stop everybody's fun," Ian Rice tells me. "We are people that play games, that like games, that are just trying to help parents make informed decisions. We're just regular, normal, down to earth people that are making these judgements day to day." We sit on a sofa in a hallway with a person vacuuming loudly nearby, and Rice and Lapper tell me how it's all done.
There are stages to getting a game rated. The very first stage, if someone wants it, is informally asking for advice. I see this first-hand when Lapper temporarily leaves the conversation to talk to some indie developers making traditionally adult-themed games for younger audiences, which sounds intriguing. They want advice on what they can and can't do, and Lapper and Rice are happy to give it. "We want to help," Rice says.
The next stage is the beginning of the formal process, which happens around three months from a game's release. This involves a self-assessment form and ticking - and then explaining - which of the 35 criteria apply to your game. "So they've said, 'Yes, my game contains mild bad language. It's got 'shit' and 'bastard' in it," Rice uses as an example. I grin childishly - I'm not used to hearing it put so matter-of-factly. There are boxes for more severe language and racial slurs, and there are obviously boxes for violent content and sexual content and everything in between.
The next step is supplying short videos alongside the explanations of what's in your game. This verifies that it exists and it also helps the GRA see if you've understood what you're submitting. Let's use violent content as an example: "Did they understand if it was realistic or unrealistic?" Rice says. "Is it an 18 category of violence, so is it gross violence, torture, violence towards vulnerable or defenceless characters?"
Here, there's an opportunity for a dialogue to occur. It's not a submit-and-done kind of process, but one that can go back and forth and potentially affect - adjusting one way or another - the overall rating of a game. "You get some publishers that are aiming for 16 and there'll be a particular criteria that caught them off guard versus, say, the ESRB in the [United] States," Rice says. "So we might say, 'Because your character was restrained in that chair, they were tied up, that's actually an 18 characteristic here.' So do you want to untie that character that's being interrogated? You could possibly end up with a slightly different rating. Or if you take that particular word out, you're not going to get a 16, you'll get a 12, which are easy adjustments to make."
Usually around two-and-a-half hours of video clips are supplied for every game, they say, plus cut-scenes, plus the entire script, which is much easier to automatically scan for bad language.
Once the videos have been watched by the examiners, the final stage is playing the game itself, not in order to complete it end-to-end, but to double-check there are no hidden surprises. "So what happens if I use a bazooka or I use a grenade launcher," Rice suggests as an example. "Is a limb going to be blown off? That will jump it from 16 to 18. What happens if I shoot a hostage? Again, that's a rating jump. Can I run over a pedestrian? That's another rating jump." Then, the rating is issued.
A rating can have a significant effect on the size of the audience a game can be sold and marketed to, and with anything that carries that kind of significance, pressure comes along with it. Sometimes, publishers don't like the outcome, and sometimes they push back. "Unfortunately for them," Rice says, "it's a case of, 'We've seen this particular type of content. If you're not going to take it out, we don't have a choice. We're going have to issue this rating.'"
There's a formal appeals process should it be needed, though, and this is run by a group that's independent of the Games Rating Authority. If this group decides the PEGI criteria hasn't worked for a game - "It's never going to be perfect," Rice accepts - an experts group will be informed that will possibly change the criteria itself. The PEGI criteria might be black and white but it's also subjective, Rice realises, and it changes all the time.
For instance, one long-standing complaint about PEGI ratings was that superhero violence - the sort you might see in a Marvel superhero film or in Star Wars - was treated more strictly in games than in films. The BBFC would classify a film with a 12 rating, whereas PEGI ratings would require a 16. We wrote about this way back in 2011, so it's been going on for a while. It became a loud talking point when Star Wars Battlefront was release in 2016. But it's not a problem any more. As of about 18 months ago, games are now aligned with films, in that as long as there's no blood or or obvious injury or harm, violence can be waived in a 12 rating.
"PEGI's always been relatively... I don't want to say severe," says Rice, "but it's been quite strict on content. In some cases that's created disparity between other forms of media, and the danger is if you're classifying too harshly, parents will think-"
This is where Craig Lapper chimes in, having worked at the BBFC for 22 years. "It was producing amongst parents and young people this feeling that there was a disparity between essentially the same kind of material," he says. "But the rating changes, adjustments to criteria, can go both ways." A 16 criteria for horror was introduced in 2020, "because there was a feeling that that in itself was not being treated strictly [enough]."
I wonder whether, with the ever-increasing fidelity and adult nature of games, they've seen an increase in violent or sexual content, but apparently they haven't. The PEGI rules on sex are quite clear - sex without visible genitals, PEGI 16; sex with visible genitals, PEGI 18 - and no games have pushed beyond that. So far, they've never had a game considered pornographic enough that they had to refer it to the R-18 department at the BBFC. It's a similar situation with violent content - there are violent games but they're behaving according to established rules.
"There's certainly subject matter for games that always takes us by surprise - I don't think we've seen it all and I don't think we ever will," Rice says. "[But] there's not very far you can go after dismemberment, decapitation, torture, that kind of thing. We've not really seen anybody really try to push that ceiling because although you might get a PEGI 18, there are other territories in the world that would just say no."
Some publishers might argue that America's rating board (ESRB) was more lenient on violence than the PEGI ratings, but it's a door that swings both ways. "You just have to explain in those instances we are dealing with different cultural standards," he says, "and whilst we might be stricter on certain types of content, we're more lenient on others." Sexual content and crude humour are treated more leniently here. Were a game to have visible faeces or audible flatulence in America, for instance, its rating would be pushed up (at least at the lower end of the scale). In South Korea, meanwhile, games cannot erode the national identity of the country. "We don't really care from a PEGI perspective," Rice says.
But there is a topic that's emerged in recent years that remains divisive: in-game spending and gambling. This includes things like loot boxes and the card packs in EA Sports FC Ultimate Team - concealed purchases with random elements to them. PEGI treats in-game spending as a separate issue to the content of a game, meaning it provides a separate label to highlight that in-game spending is there. "We decided to keep that as a separate issue from the contents because we want, at its core, PEGI to remain a content rating system," Rice says. "If you start factoring in things like spending, you lose the nuance between the content. You don't want FIFA and Call of Duty having the same rating next to each other, side by side in the shop, because as a parent, you're not going to be able to determine what's suitable content and what's not."
That's fine until a puzzle game like Balatro comes along, which is themed around the card game of Poker, and it gets a PEG-18 rating because it's deemed to promote a form of gambling. EA Sports FC gets away with a PEGI 3 rating, whereas Balatro is removed from sale in some countries. It's been a very controversial ruling. "I think the one thing I am most disappointed by," Balatro creator localthunk said in response to it, "is the fact that other games with actual gambling mechanics aren't rated the same way because of their appearance/theme."
I ask Rice about this. "We were responsible for Balatro's 18 rating," he says, "which we believe was the right decision. The PEGI criteria requires games that teach or glamorise gambling to be rated 18, and after close examination we believed there was sufficient content in the game to teach someone fundamental skills and knowledge useful in poker." That's fair enough, but which game will have a more harmful overall effect?
That brings us to a question which has followed PEGI ratings - and will always follow PEGI ratings - for as long as they exist. How effective are they at keeping the wrong kinds of games out of children's hands? It's worth noting that while PEGI ratings are enforceable by law in the UK, they only prevent a shop from selling a game to an underage person. They do not - as with alcohol and tobacco - prevent a shop from selling it to an adult on behalf of an underage party. PEGI ratings are, primarily, there as guidance for adults.
"In terms of how effective we think the age ratings are," Rice says, "we do regular public consultations, and we do ask parents. And parents have told us that: 84 percent of parents find PEGI ratings useful and 86 percent trust PEGI ratings." These figures don't quite match up with what's listed on PEGI's website. There it says that 79 percent of parents with children who play video games are aware of PEGI age ratings, and that 76 percent of those parents use PEGI labels when considering what to buy. Almost of half of that figure (49 percent) use the age rating labels and follow their advice; 27 percent use the labels but do not always follow the advice; and one in four pay no attention to the labels when considering which game to buy for their child.
"It's there for people who want to use it," Rice says. "You will always have parents let their kids play games that are not exactly bang on the age rating. They're making a decision based off of how they know their child, which is absolutely fine. All we ask is that they're making an informed decision." It does help, Rice says, that parents are increasingly people who grew up with games.
Today's game sales being predominantly digital does come with a drawback for PEGI, in that there are fewer boxes to stamp PEGI logos on. A child no longer needs an adult to buy the game in a shop for them, so that moment where they physically pick up a box and see rating on it has gone. Age ratings still exist at the point of purchase on nearly all of the major game-selling digital stores, such as the PlayStation Store and the Xbox Store - although only optionally on Steam - but how many parents are still actively involved in the buying process of games on them?
It's a never-ending quest for visibility - for awareness. The more the PEGI age-ratings remain present in people's minds, the more people are likely to make decisions for children based upon them. That's why Rice and Lapper are making an effort to get out there and meet people face-to-face, why they're sitting near an elevator with me now. "We've been told we've got a good system but potentially more people could know who does it!" says Rice. It's why the Games Rating Authority now has a TikTok account.
But the biggest champion for PEGI ratings will always be the game trailer - or any other kind of advert - where it has to be displayed. Richard Wells' deep and posh voice still does so much heavy lifting for them. It's a wonder he was only apparently paid €200 (£170) for his work. Rice and Lapper have seen that TikTok video by the way. "So yes I've seen it," Rice says, "but that is something that's been handled by PEGI in Brussels. I don't want to pass the buck and say it was before my time but it was very before my time! Arrangements were made at the time and I don't know the details, but that's in PEGI's court to handle that," he says.
I leave Lapper and Rice as they move onto advising a pair of independent developers about their upcoming game, and I'm sure they will have many more informal conversations like it over the few days the Brighton Develop conference runs. I leave knowing a bit more about how PEGI ratings operate and who operates them, and with it no longer a faceless organisation in my mind.