The CEO of TIGA, Dr Richard Wilson, has written an open letter to Simon Little of PEGI, the European game content rating system, calling for urgent reform of its pricing policy, which charges small games businesses unreasonably high and repetitious fees. TIGA has acted in response to complaints from its members about PEGI's pricing policy.
I am writing in response to complaints from TIGA members about PEGI's pricing policy. In particular, the pricing policy that comes into effect from 1st July 2014. It is excessive and unreasonable to charge a developer a fee for content rating every time it launches a game on a different console platform, even if the content is exactly the same. TIGA recommends that the fee for age rating the same game content for different platforms should be scrapped entirely. PEGI's current approach risks hurting start-ups and small independent developers.
Additional platform fees
As you know, PEGI has a monopoly on games released in Europe, Germany aside, and the majority of platform owners have a mandatory requirement for age rating certification. Developers cannot therefore realistically avoid certifying their console games via PEGI in Europe. PEGI's policy of charging a fee for content rating every time it launches a game on a different console platform, even if the content is exactly the same, can impose costs potentially running into thousands of euros on UK and European developers. For example, the ratings fee for a 'Lower Development Cost Product' (where the game's budget is less that €200,000) is €1,155 in the first instance and €1,050 for each additional platform thereafter. So if an indie developer was to launch the same game with exactly the same content on PlayStation 3, Xbox 360 and PS Vita, they would be looking at a ratings bill of €3,255. PEGI's pricing policy imposes disproportionate and unnecessary costs on indie developers pursuing a multiplatform strategy.
TIGA believes the PEGI content ratings system should be focused on providing information to consumers and protecting vulnerable consumers from accessing inappropriate content. However, this must be achieved without burdening small games businesses with excessive costs. TIGA recommends the fee for age rating the same game content for different platforms should be waived entirely. Many small development businesses operate on a knife-edge and struggle to conserve every pound or euro they can in order to stay in business.
TIGA further suggests that PEGI could examine the potential for delivering its rating system more efficiently. At present, PEGI carries out the rating process repeatedly for games on multiple platforms. We recommend that developers could instead be offered the opportunity to sign a legally binding document stating the game content is identical. This would allow PEGI to provide a single multi-platform age rating, which in turn would save PEGI's time and indie developers' money. TIGA would be happy to approach TIGA member Stevens & Bolton to draft this legally binding agreement and make it available for free to indie developers.
An un-level playing field
The majority of UK and European games developers operate small studios where financial resources are limited and costs need to be kept to a minimum. TIGA's policy is to strengthen the game development and digital publishing sector, in particular by saving games businesses money and improving their access to finance (hence TIGA's long campaign for Games Tax Relief). PEGI's pricing policy imposes damaging and unreasonably high fees, which have a disproportionate impact on small games businesses. It cannot be right to charge a developer a fee for content rating every time it launches a game on a different console platform even if the content is exactly the same.
Significantly, US developers do not have to pay their equivalent ratings body, the ESRB, anything at all for rating identical content on additional platforms Once again, UK and European developers are being put at a disadvantage. If the UK and European development sector is to thrive then we need a pricing policy from PEGI which is helpful, not a hindrance; is proportionate, not punitive; and is equitable, not exorbitant.
To summarise, it is disproportionate and unreasonable to charge a developer a fee for content rating every time it launches a game on a different console platform, even if the content is completely the same. TIGA proposes that the fee for age rating the same game content for different platforms should be scrapped entirely. PEGI's current approach risks harming start-ups and small independent developers.
I trust that you will give the contents and suggestions made in this letter serious consideration. TIGA would be pleased to invite you to a meeting to discuss these issues further with TIGA representatives so that we can find a solution that fairly represents the interests of developers, digital publishers and consumers across Europe. Given the importance of this subject to TIGA members, we intend to make the contents of this letter public.