The public consultation on the introduction of an R18+ for computer games closes at the end of the month. Jessi Citizen, on behalf of EFA and in conjunction with Ausgamers, has prepared a draft response to the consultation that sets out our understanding of the issues and our arguments.

In the spirit of community involvement, and to ensure that we have the strongest argument we can possibly put forward, we are opening this draft paper for public comment. You can see (and edit) the paper on Google docs. Please provide us with your comments and suggestions on this paper. In addition to the draft document, we also have some research that we conducted (thanks to Julian Merlo and Matt Postle) that details comparative ratings for games in 2009 worldwide (showing that over half of the games that were rated as MA15+ here were given adult ratings by all five comparative jurisdictions overseas!)

To join in our discussion on the draft paper process, please join our discussion list. Putting these documents together takes money, and EFA is entirely volunteer funded. If you would like to contribute to our R18+ submission, please consider making a small donation to help us recoup our costs:


In addition to comments, we would like to see as many people as possible put together their own submission to the public consultation. You can do this either by using Grow Up Australia's submission form or following the submission template and the instructions on the AGD's website.

Here's some tips for writing a submission:

  • Be reasonable; don't attack the classification board or any particular Attorneys-General. We have the facts and the theory on our side, and we don't gain anything by sounding childish or petulant.
  • Follow the submission guidelines - make sure your voice is heard.
  • Make your points clearly and succinctly. Feel free to take any of the information we present in the discussion paper; you're usually better served by being brief and to the point.
  • Express the issue in your own words, and tell your own story; Explain to the AGD why you personally want an R18+ rating, and how it affects you.

The main points that we are trying to stress in this discussion paper are really quite simple:

  • Gamers are adults; games, like films, tell expressive stories, not all of which are suitable for children. Banning everything that is not suitable for children amounts to unacceptable censorship of legitimate expression.
  • Gamers are parents; as responsible parents, we take care to monitor what media our children consume, and can take responsibility for those decisions.
  • An R18+ rating is about empowerment; the goal of Australia's classification is to empower adults, protect children, protect people from accidental exposure to offensive material, and to take into account community concerns about particularly offensive content. An R18+ allows adults to choose what is suitable for themselves and for their children.
  • An R18+ rating will be more likely to decrease rather than increase the exposure of children to inappropriate content, because it sends a clear message to parents that certain material is not appropriate for children; the lack of an R18+ for games, particularly when one exists for films, only causes confusion and lessens the ability of parents to take responsibility.
  • Australia's system is out of step with the rest of the world; games that are clearly not designed for children are being released with an MA15+ rating, and games that are suitable for adults are being banned. Our research shows that of the 47 games that were rated by the Australian Classification Board, the US ESRB, the UK BBFC, the EU PEGI, and the NZ OFLC, more than 50 per cent of titles that were rated MA15+ in Australia were given an adult rating overseas. The Australian system is demonstrably less effective in warning parents and gamers about the content of video games than our international counterparts. Introducing an R18+ rating will address some of this disparity and enable Australians to make more informed choices about what games they play or allow their children to play.


  1. As an adult i find it troubling that there is no R18 rating on video games. Why should the adult population suffer because of chances minors could play unsuitable video games. As soon as i hit 18 i was legally able to drink alcohol, smoke tobacco and buy hardcore pornography. Why not ban alcohol and tobacco because of the severely negative effects that it causes on the human body, this includes cancer, liver problems, heart attacks and even death. Tobacco and alcohol is statistically proven to be one of the highest causes of death in Australia so why is it i am allowed to consume them? Ill tell you why, its because the government receives billions of dollars in tax from them.

    Come on Australia, get it right for once. Even you can see there is money for you to make here. So if not out of common sense, introduce an R18 for the sake of your pocket.

    Comment by Grant on 5 February 2010 at 06:04
  2. Sorry to be a nuisance but would it be possible to get a copy of this draft in .RTF or .PDF, as I don't have anything to open .DOC with.

    Comment by Anonymous on 5 February 2010 at 06:40
  3. Dear anon, you can use the google docs link to view in a web browser; I'm only going to generate a PDF when it's final. If that's not sufficient, let me know and I'll export to ODT or RTF.

    Comment by Nic on 5 February 2010 at 06:42
  4. Sorry, I completely missed the Google docs link. That is entirely sufficient. Thanks very much.

    Comment by Anonymous on 5 February 2010 at 10:28
  5. you don't think the fifth point might backfire on us, and be interpreted as "oh, we'd better be stricter in banning games!" and then they'd increase the amount of games being banned, whilst trying to enforce more rules on what can and cannot be in games? hmm... but otherwise a good point

    Comment by Anononon on 5 February 2010 at 22:51
  6. No to be picky, but I would like to point out an error in a sentence:

    Page 6, last sentence of the first section: GAMERS ARE PARENTS TOO. The last sentence reads:

    "According to, 4 in 5 Australian parents are influenced by the Classification Board’s ratings when buying video games for their parents."

    Should that read "According to, 4 in 5 Australian parents are influenced by the Classification Board’s ratings when buying video games for their children." (children being the only word needing to be changed).

    If the first sentence is correct, I retract what I have said in this post :-).

    Comment by Andrew on 6 February 2010 at 04:04
  7. Anononon: I don't think so - I think we need to accept that our classification system would be improved if we could rate games R18+ without banning them, and I think it's legitimate for us to make that point.

    Andrew: yes, you're absolutely right. We'll make the change.

    Comment by Nic on 6 February 2010 at 04:09
  8. As technology gets better and we can do more and more with it (in terms of game development) the classification board should align its self with the ever changing landscape of game development, not just in Australia, but around the world.

    For example, when games like doom and quake were released (I cannot remember the date, but mid 90's somewhere), it was considered very violent, possibly disturbing, vulgur etc. With todays standards, it no more violent, disturbing, vulgur than comparing it to say the The Simpsons in the early days when people thought it was rude and crude, compared to current main stream cartoons such as Drawn Together (Which I think is funny) but far more rude and crude than what The Simpsons used to be (in my opinion). While Drawn together has received an M15+ rating (correct me if I am wrong), the classification has shifted allowing more rude and crude shows in at similar levels at which shows that where never that rude and crude received a similar classification many years ago. So you can start to see where I am drawing my opinion from.

    This is by no means an informed/research point, rather an observation I have made over a period of time.

    Comment by Andrew on 6 February 2010 at 05:00
  9. Can I ask, say they made a movie which would be rated as R18+ in Australia. Then a gaming company makes this same movie into a video game which includes, the same level of 'gore' in it as the film itself. A mirror image if you will, a movie that has a game that is in perfect replicate of itself. How can it be justified if the movie is given a rating of R18+ while the other would be deemed inappropriate and refused classification?

    As I've followed this story for sometime now, reading the many articles and reply's from the Attorney General... it appears that keeping the current rating on Australian games, only puts more harm than good on the youth of Australia. Protecting our youth was more important for the banning of games than allowing our rating system to do its job.

    I'm 22 years old, and I've been a gamer for at-least 12 years. I don't play a violent game because I want to see someone blown into millions of pieces with blood all over the wall. Just because I view this and make the simulated actions "pressing a button using my hands", doesn't mean that I'm inspired so much that I'd choose to go out and attempt the same fate on a helpless person, or someone evil "if I were in a vigilante mood". It would be like viewing the movie Saw over and over to watch how to murder someone in a horrible way, then taking part in these actions. Its just not going to happen, period. People make these horrible actions because of reasons that generally most persons cannot comprehend or explain.

    The game doesn't tell me what to do, I tell the game what to do. It just sets the path and my actions are my own.

    As Andrew said "This is by no means an informed/research point, rather an observation I have made over a period of time." sorry Andrew for stealing that.. :P

    Comment by Kristian on 6 February 2010 at 07:41
  10. I'm not sure if this is any help, but my mother asked me my opinion on whether a game was suitable for my nephew. We came to the conclusion that a lot of people would think "well, my child is pretty mature... what's 13 years old to an MA15+ game? It's only a difference of two years."

    But of course, this was Modern Warfare 2 and if a person who thought that saw an R18+ rating, they'd think twice about letting their 13 year old play an 18-rated game. Where people might think their child is ready for a game two years below the recommended age, given over half of the 15 ratings should be 18, it's no longer a two year difference. It's a difference of five years, which is a lot of time for someone to mature.

    So basically, it's misleading to not have an MA15+ rating. Dangerously so. If that's any help...

    Comment by Dane on 6 February 2010 at 08:14
  11. I can see both sides of this debate, First we have a attorney-general trying to set a good example to people to try and block mature content from games to "Protect" the children, The other side to this is the fact we have R18+ movies that come out, I admit i have not seen all the saw movies, However they where only rated MA15+, Whilst Hannibal had a Ma15+ for 2 weeks than went to R18+ Now from what i watched in saw, It made Hannibal look like Teletubbies, Now they are making a Game to saw, Which is having a MA15+ rating, Now Apparently in the Last Saw movie you see the actual head trap snap shut on a person, And too anyone who has seen the actual trap before they realize how much damage it can do, Now to implement that into a game with a MA15+ rating is just a bit over the top, I agree with you guys on a R18+ rating, I believe the Govt believes we just want it implemented for the actual sexual content rather than just not being up to date with the world ((And i have no doubt that, That is why some people want a R18+ rating))I do believe Australia is behind the times in everything, It is anew decade and it is time for some changes, The implement of the New internet system being done over the next 7 years is the first step to get us up to date with the standards of the world, And hopefully, With all the support and petitions etc this R18+ rating is getting i hope it passes, I am 19 years old, My opinion may be heard but not recognized by many as i am young, However i just hope people read this and just help to get this all done so we are not primitive with games anymore,
    P.S, Sorry for the long comment>.<

    Comment by Joshua on 6 February 2010 at 10:23
  12. I feel that the classification system should be just that, a way of informing buyers of what the content is. The current system effectivly bans games and is a form of censorship. This censorship goes beyond the role of a board of classification. It is not in the interest of the citizens or the governtment for this kind of control to occur. The choice of what we want to buy must be in our hands and not a minority with individual with their own political agenda.

    Comment by Michael on 7 February 2010 at 02:48
  13. As an ex-employee of a company that sold games, one of the hardest things I had to do was sell games to kids that I thought were completely inappropriate for them.

    For example, GTA: San Andreas and GTA:IV are games which I believe a 15 year old should probably not have legal access to. Even worse, younger kids were having the game bought for them by their parents and I had to instruct them to watch the game being played as the classification rules were not similar to that used in MA15+ movies. Many parents after seeing the game played came back and asked for a refund based on my advice, saying that this game should only be for adults and were largely shocked when told that there was no such rating.

    Furthermore, how as a retailer are we meant to judge if a person is 15 years old? Are persons aged 15 years meant to bring their passport or birth certificate? There is no other way that I can think of to ascertain the age of someone under the age required to get a driver's licence in a safe manner.

    I think the arguments for allowing an R18+ classification are not only to allow more games to be available to an adult audience who have a right to play them, but also to allow the MA15+ classification to accurately reflect what parents expect from such a rating.

    Comment by Josh on 12 February 2010 at 19:39
  14. cmon australia r18+ movies are much wors becuse some of them are actual people getin butched and guts evrwere but games a cartoons tht are not real and not as bad as real life movies with r18+ movies parents let them not watch it so whats the diffrence between keepin em away from r18+ games like people under 18 are going to go to the shops and buy it becuse they cant becuse its rated not for them

    Comment by Dylan on 23 February 2010 at 07:14
  15. Gamers are adults !!! Give Games a Rating classification !!!

    Comment by Peter Shepherd on 24 February 2010 at 02:55