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At the MAD Games Show in Madrid we attended her panel and then caught up with Pan-European Game Information's Senior Operations & Communications Manager to talk all things PEGI, including the newest introductions to deal with interactive risk, (loot boxes, unrestricted chat, pressure to come back), but also to discuss how PEGI operates in different countries and with the different platforms and publishers, as well as the important matter of awareness for children and parents.
"Hi Gamereactor friends, I'm at the MAD Games Show in Madrid, which has been organized by the unions closer to the studios and the publishers here in Spain.
There are talks, other than indie games, there are talks and meet-to-match and meetings, etc.
And one of the talks I just attended is by you, Jennifer, thank you so much for joining us."
"You came from Brussels, if I'm correct, and you are with PEGI. PEGI 16, PEGI 18, you know what that is.
It's the rating system here in Europe, in many countries, as you just mentioned.
But, you know, it's a hot topic because you, last week, announced a few changes in how you guys deal with games that can have risk of interactivity.
Interaction risk, absolutely."
"Two ways, right? One thing is loot boxes, always controversial, and also how you can communicate with others, right?
Yeah, and also pressure to play, to come back to the game. So there are a few elements that we have added here, so it is really important to...
This is the biggest update PEGI has ever done, I mean, because we are extending the scope, not only to content of the game, so that is what's really the focus at the start on violence, bad language, drugs, sex, and all that."
"Now it's really extending to elements that are more like features, mechanisms in the game, such as in-game purchases and paid random items, pressure to play to come back to the game at certain specific timings, and also the online interactions in the chats and so on.
But what is really, I think, important to raise is that those criteria have been just announced now, and we will implement them in June, so from June, the games are going to get those new criteria, and publishers will have to answer those questions."
"And then after that, we will see the ratings coming, I think it's going to be around the end of summer, or beginning of September, when the games are going to be released, actually, and we'll display those new criteria.
So this is really a big step for PEGI to actually extend it to really context, because we have seen since a few years, actually, because we already added the in-game purchase descriptor in 2018, and the paid random item feature notice in 2020 as well, but those were not triggering an age, so that is the difference."
"I mean, we were already obviously very much aware of those mechanisms, and wanted to inform parents and consumers about this, but now those elements are going to trigger an age rating.
Certain types of in-game purchase, like, for example, when there is time-limited quantity offers, such as battle passes and so on, that's going to trigger a 12, for example."
"Or paid random items are going to trigger a 16 loot box, gacha system, all that.
Pressure to play, so to come back on a daily quest, and certain initiatives to come back to the game at seasonal moments and so on, that's going to be a PEGI 7.
And if the user would lose content because they don't come back to the game, that would be a PEGI 12."
"And then the online interaction, we also require to have a reporting mechanism, you know, if you ask for a PEGI rating.
But now there is also this extra criteria asking that if you don't have moderation in your chat, in your functionality, to communicate within the game, so that as a user you can't block or mute another player and so on, well, that would be a PEGI 18."
"If it is fully unrestricted.
If it is not restricted, and no moderation, let's say.
So those are quite an important step for the self-regulation system.
They are very important for both the community of players and parents, and also for you as a regulator of this."
"And I also guess it's been a long time coming.
So what can you tell me about the process and how you've been trying for years to define what you can do in this respect that has been concerning many agents and families?
Yeah, absolutely."
"So we've got several committees.
We've got an experts group from all over Europe, experts, academics, specialists in minor protection and so on, who have been looking at the criteria.
We also have a PEGI council with representatives from the different countries, ministries and media authorities and so on, who also have contributed."
"And then obviously our administrators, NICAM and GRA, who are actually testing the game and seeing all those content, seeing all the new technologies, features, mechanics and so on.
And so I think indeed, I mean, it's been almost 18 months to develop those new criteria and to have a consensus and an agreement for everyone within those committees, but also to develop really objective criteria to determine which one would get which rating."
"And because we have a questionnaire with 35 questions that the publisher answers for his game, and now we are adding more than 10 questions.
So it is quite a lot.
So it is a big upgrade."
"But there's been a big consensus among those committees to actually reach those elements.
And it has been also influenced, I guess, by USK, you know, the German system, federal system, because they have integrated those new interaction risk criteria since two years.
And so we could actually learn from their experience."
"We have collaborated a lot with them too.
And so while trying to develop this on our side as well.
So I think this has been really useful for us.
And as I said, it's hot news because you announced last week."
"And what sort of feedback did you get from publishers?
Are any of them concerned over potential sales loss to this new PEGI system?
I think that the news was very well received, quite positively.
Obviously, not all publishers and companies are happy with it."
"But I think it was needed.
It was expected.
And, you know, it was a very, very big request.
I mean, coming from parents, consumers, governments and everyone."
"So I think the industry just wanted to also take the responsible step here to actually disclose all this and to have like a proper rating.
I mean, industry representatives, some of them have been involved in our board as well.
So it is not like they didn't know about this."
"But obviously, for some companies, it might have been quite a surprise when we announced it in March.
But I think everybody will have to adapt and adjust and either take the rating or take some incentive or initiatives to change maybe the design."
"If they don't want that rating, that's up to them as well.
That's from the publisher's side.
What about the families and the parents?
Sometimes I feel like there's a lot to do in terms of awareness for the PEGI system."
"I, myself, as a dad, see that, you know, some kids, very young, they get access to PEGI 18 rated games.
So I know you have your initiatives in this regard.
So what can you tell me is left to do for the message to reach parents when they go buy physical or digital products?
And also now that you introduced these new restrictions."
"Yes, I think there's a lot of communication to do.
Education, communication and information to parents and consumers on national level.
As you know, PEGI is in 40 countries, European system.
So there is a lot to cover."
"And also even more with those new criteria to actually explain why that rating got a higher rate, that game got a higher rating and so on.
But actually, it might be the start of the conversation as well for parents to see, oh, why this game got that rating?
Then they will look a bit more at why it got that rating."
"So we're going to put text descriptor.
We're going to try to inform as much as possible on this at national level and at European level as well.
But I think as a parent, PEGI remains an information, an advice, a recommendation."
"But it remains the role of the parent to decide what's best for their children, to actually choose.
Every game is different.
Every child is different in terms of sensibility as well."
"I mean, I'm also a mom.
I've got two girls, so I know.
And I think that you need to find some ground rules like agree, ideally, you can set up parental control tools, select an age rating, but also decide on timing, that you can play a bit more during the weekend and the holiday."
"And then that you can find some rules and then decide on purchase, for example.
Do you want to give some pocket money for that?
Or actually, do you want to put the spending off by zero, off by default until a certain age?
That is up to the parent to decide."
"That is what we really want to have as a message, you know.
I mean, you can't do it without the parents anyway.
So, yes, there might be some kids having played with higher rated games, but at some point, this remains the decision of the parent."
"Perhaps more penetration into schools and education systems.
Absolutely. Teachers, I know, many are speaking about PEGI and using games in class as well.
Also at retailers, you know, in the shops as well, to give some more information."
"And I think that's going to be very important with the new criteria coming in.
Because otherwise, I mean, for a parent, it's very challenging as well to understand everything and to, you know, be informed on those things and then have the decision and the discussion with the children, sometimes conflict on that."
"So it is not easy. We definitely understand that.
But we just hope that with giving the ratings and the information about that, that what is in the game in terms of content and mechanics, that it will help them to take an informed decision and to choose, actually."
"All right. And you mentioned the number of countries you are present in.
Of course, not Germany, as you mentioned.
The USK is a different type of system.
So what can you tell me about that?
Because we are present in many countries around Europe as Gamereactor."
"About the countries you are present in, the potential countries that might be joining in the future, or the differences between the different countries that are part of the PEGI system."
"Yeah, it is indeed.
PEGI is applied in different ways in all those countries.
Sometimes it is just present on the market.
Sometimes it is officially supported by the country since the creation, for example."
"And then sometimes we have representatives from the country in our committees.
And then sometimes it's even in the law.
So it becomes like a co-regulatory system, you know.
It is mentioned officially in the law, as in the UK, for example, or in France as well, it is mentioned in the law."
"But then sometimes it is also enforced at retail.
So, for example, in the UK, you need to respect the 12, 16 and 18 category in the shop at retail as well.
So there is a big variation of use and interpretation of the system."
"It's always present on those markets.
But then the support and integration in the regulation and in the law is different per country.
That's about the countries."
"But then there are platforms.
Digitally, I asked you on stage about this, but I wanted to ask you about the same thing on the record as well.
You're present in several digital stores, such as Nintendo's, Epic Games store for PC games."
"But what about others that are not present, such as Steam or Apple?
Yeah, those are the two platforms where we are not present.
Apple has its own rating system in-house since the beginning.
So we try to discuss with them."
"But so far, they are keeping their own system.
And then Steam doesn't have any system or mandatory system in place.
They do allow publishers to display the PEGI rating if they have one.
But that's it. And many don't."
"So that's a bit unfortunate because they are a big player of the industry.
So we would be very happy to discuss with them and see how we could integrate PEGI more.
I will ask them about that."
"And almost final one.
Something interesting that you mentioned is...
How did you put it?
Okay, you said we don't ban, we don't censor."
"But if you don't follow the rules and the guidelines you agreed to with PEGI, you can get suspended and you can get fined.
So I think many players and people in the industry don't know about this.
Can you give us a brief description about how it works?
Absolutely."
"Indeed, as PEGI, we deliver a rating.
We give you a rating for your game.
We don't censor, we don't ask you to remove any content from your game.
We could give you a PEGI 18, PEGI 16, whatever."
"But we don't ask you to remove.
Sometimes the publisher or developer decides to remove some of the content, sensitive content, because they are trying to get into a specific age bracket.
But that's up to them."
"And then, indeed, we don't ban games.
We always deliver the rating.
And then after that, some countries, national countries, authorities, or sometimes platforms can decide that they don't publish the game or that they don't want to distribute the game."
"But again, that is up to them.
And then, lastly, what was your last question again?
You don't use sanctions or remove...
Absolutely, because I think what is important to also say is that behind PEGI, behind the labels, it's not just a self-classification content system."
"It's also a self-regulation system.
We have a code of conduct.
So each time a signatory, a member actually wants to have a PEGI rating, he's signing a code of conduct with us and he's respecting all those rules, such as, obviously, full disclosure of content of the game, responsible advertisement, displaying the logo properly, but also rules about in-game monetization, transparency, safe online, online safety environment, and so on."
"So such as having, for example, reporting mechanism, privacy policy, community standards.
We do ask much more than just delivering the label.
But then, after that, obviously, if there is a breach of the code."
"So, for example, if we see that the label is missing from the packaging or that there is some content that has not been disclosed, that we receive a complaint from a consumer saying there is bad language in this game, why is it a PEGI 7, for example."
"You have to work with them after release.
After, of course, of course.
We do receive the package with the label that is printed.
We check the retail copy."
"And then, after that, we will be in touch with if consumers are coming for complaints, or publisher can also make a complaint.
Then we're going to discuss a lot with the publishers and developers."
"And we're going to see where there has been an issue.
And we have an enforcement committee who is actually going to look at the breach and then can indeed deliver sanctions and fines."
"That makes the whole system robust, I think.
And final, final one.
You mentioned disclosure of content in games.
You, of course, have access to in-development games and mostly descriptions."
"Sometimes we see a lot of games being leaked by other age rating systems.
Normally not by PEGI.
Because you guys get access to titles and descriptions for titles."
"So, what can you tell me about this?
About working with in-dev titles that sometimes, as you just mentioned, change when they get to the final version or release."
"And also about confidentiality and how you deal with all this.
So, we have a rating website just for our members that is very, very confidential and controlled."
"It's a huge database, as you can imagine.
And they submit the games way much ahead or before they're going to be released.
Because they need that provisional rating for their marketing."
"They need to know exactly what rating they're going to have, the license for packaging and everything.
So, they do that much in advance."
"And it's only when the release date hits, so when the game is released, then that entry goes on our public website.
And then the information is disclosed to consumers and everyone."
"But we do have, obviously, a strict policy on that and are very careful.
It is very much confidential.
The ones that are adhering, that are testing the games, examining the games."
"But, obviously, that remains under strict confidentiality.
Fantastic.
How would you rate this interview?
PEGI...
PEGI 12, I would say?
Out of complexity?
Well, not complexity, because it's not..."
"You didn't swear? Any bad words?
It's not about difficulty.
I'd say PEGI 3.
I didn't say any bad language.
PEGI 3."
"For all audiences.
Yes, absolutely.
It's been a pleasure.
Thank you so much for your time, Jennifer."
