Age rating in Virtual Reality Environments

Written on 11 Aug 2016

The rapid development of virtual reality technology lets players immerse themselves into digital worlds, and additional accessories introduce a physical experience to gaming, letting gamers feel vibrations and even punches. It is yet unclear, however, how such optional hardware affects age ratings. Up until now, the hardware used to play games has never been in the focus of classification procedures. Dedicated virtual reality content will however require a differentiating view, which will also pose technical challenges for ratings organizations.

Video Game Age Ratings in Europe

The European rating system PEGI (Pan European Game Information) rates games into the following five categories: 3+, 7+, 12+, 16+ and 18+, and gives additional guidance through content descriptors. With the exception of Germany, PEGI is used in most European countries and beyond, e.g. in Israel. PEGI reviews for games 3+ and 7+ are conducted by the Dutch NICAM institute, while the British Video Standards Council (VSC) (acting under the alias name of Games Rating Authority (GRA)), reviews 12+, 16+ and 18+ rated games. Based on PEGI procedure, the British VSC/GRA also grants age rating certificates for the UK.

Under the German federal Youth Protection Act (JuSchG), video games distributed on physical media (e.g. DVDs or cartridges) may not be made accessible to minors unless they have a state-issued age-rating. Classifications are provided by industry self-regulation body USK, which rates video games are rated in five categories: “without age restriction”, 6+, 12+, 16+ and “without clearance for minors” (i.e. 18+). Media considered harmful to minors are denied classification and can be listed on the so-called “index” by federal authorities, resulting in severe distribution restrictions.

On an international level, a group of rating organizations including the USK, PEGI and others has created the International Age Rating Coalition (IARC), which operates an international rating framework for (participating) app stores; this system, therefore, applies for digitally distributed games only.

Enforceability and Sanctions

The UK requires an age rating for games only suitable for age 12 or higher, and entirely prohibits the sale of such games without a rating. In the Netherlands, selling or renting games classified as 16+ or higher to younger persons constitutes a criminal offence (Art. 240a Wetb. v. Strafr.). Just recently, France also made ratings for games mandatory. In Austria, regulations differ between the federal states.

In Germany, USK age ratings are enforceable in retail and online. Games may not be sold or rented to a minor below the relevant age limit; even more stringent obligations apply to non-rated games included on the “index”, which for instance may not be publicly advertised.

VR Impact on Age Rating

The impact of VR technology on age rating has not been widely discussed in legal literature, but some differentiating approaches have already surfaced. PEGI is considering to re-evaluate the criteria for “fear” and “horror” once VR technology gains more market relevance, and some voices have called for dedicated rating systems for VR games.

Effects of VR on minors

VR technology has a massive influence on gameplay and degree of immersion. VR hardware introduces a completely new approach to game controls: Instead of relying only on classic controllers such as joysticks, gamepads and keyboards, VR controllers can track head and body movements and directly transpose them into game.

A study by Film University Babelsberg showed that 3D effects in movies also intensify children’s immersive experience; in particular, the effect of scenes perceived as frightening could be intensified. The authors of the study concluded that 3D movies should also be evaluated and classified in their three-dimensional version – something that is already practiced for example in Sweden and the UK. Although further research is likely needed, these results could also hold true for VR video games.

However – especially in games not developed with VR in focus – the feeling of immersion is often interrupted, e.g. when movements and interaction with the surroundings have to be controlled with a mouse, keyboard or gamepad. Especially action-centred titles like first person shooters cannot fully realize their immersive potential at the moment.

General Irrelevance of Display Devices for Classification Procedures

In principle, rating systems do not take into consideration the display devices used by consumers. A video game’s rating does not changed depending on whether the user connects their console to a home cinema system or a tiny portable TV; the classification is simply based on average consumer technology.

Most video games therefore also receive identical age ratings across different platforms (e.g. PC, Xbox and PlayStation). Exceptions are made only in cases where platform differences, such as limited hardware resources of certain mobile devices and their completely different controller architecture, result in fundamental gameplay or graphics changes. For example, “Mortal Kombat: Deadly Alliance” was rated 16+ for Game Boy Advance in Germany, while all other German versions received an 18+ rating.

Necessity of a Different Approach for VR Technology

However, specific hardware may be taken into account if it is necessary for gameplay (such as the guitar controller for the Guitar Hero games). For the German USK, such essential hardware is part of the “materials required for a proper procedure” and thus subjected to examination; German law also takes into account whether “the harmful effect of the visual representation [of violence] is reinforced through the use of reality-imitating controllers”.

To determine the effect of VR-hardware for classification procedures, it is necessary to differentiate between unofficial and official VR components:

  • Much of the VR hardware currently on the market can be used with video games without the publisher consciously having integrated VR functionality. Special 3D drivers developed by third parties add VR support to a multitude of games, even old classics like “Half Life 2”. Not all VR hardware even needs software support: Simple “force feedback” vests are for example connected to the sound card and vibrate on loud sounds. These unofficial accessories should not affect age classifications, at least not currently. This situation may, however, change with an increasing market penetration and availability of VR hardware, as a significant market share could have an influence on the “typical” consumer experience that the publisher has to expect.
  • VR hardware officially supported by the publisher, however, already influences age classification, as it is an integral, often advertised feature of the game that fundamentally changes the game experience. A short video game tech demo called “The Deep” for instance has received two different ratings by the German USK: the non-interactive version for presentation on regular screens was rated 12+, while the playable PlayStation VR demo received a 16+ rating.

Practical Impact on Classification Procedures

While current classification procedures in Europe vary, they do have one thing in common: The people responsible for the classification do not play the games themselves in their entirety. An evaluation of the special impact of Virtual Reality would however require the reviewers to play the games themselves. Game sequences shown in a regular screening lack the 360 degree surrounding display that is characteristic for Virtual Reality. On the other hand, it is essential that the field of view follows the movements of the players head. Similar problems occur with other VR hardware, e.g. tactile vests.


When rating games with official VR support, this functionality has to be taken into account for classification. Different ratings can also be given to versions with and without VR functionality. Third-party mods and VR hardware that does not require official support however should not impact classifications at the moment – the situation is the same as with any other presentation hardware. This also applies to other hardware that is not intended to be used with a game. As the publisher is not responsible, they should not be subject to distribution limitations.

This contribution is a heavily condensed version of an article from Computer Law Review international (CRi 2016, 75). We would be happy to send you a copy of the full article upon request, please do not hesitate to e-mail us.