Module 06
Age ratings: IARC and PEGI
For a digital-only eShop release, you do not apply to PEGI on paper as if this were a boxed cartridge. You complete a questionnaire through the storefront, and the rating is issued at no fee.
The official, free path for digital games
Nintendo’s FAQ: if you plan to release a digital-only title, “you can use the IARC system to retrieve the age rating for no fee, which will allow you to publish in all the participating countries.”
IARC is the International Age Rating Coalition. Its own FAQ says:
- Developers obtain ratings “through a participating digital storefront’s ingestion portal.” The questionnaire is not available outside those storefronts.
- Obtaining ratings via IARC is “free of cost to developers at this time.”
- Once the questionnaire is completed, “the ratings are issued immediately.” A simple game can take a few minutes; a game with more ratings-relevant content may take a little longer.
- Each participating authority’s own standards are applied, so the age assigned can differ by territory.
PEGI, which covers Europe and is used in the UK, explains the same digital path: the publisher fills in one IARC questionnaire as part of submitting the game to the storefront, receives a licence with the participating boards’ ratings, and the rating is shown when the game is released. Boards later check a sample of ratings and can correct mistakes quickly. PEGI also says this digital process is “cost-free.”
IARC’s public milestones page records that the Nintendo eShop deployed the IARC system for digitally delivered games and apps in 2015.
Sources: Nintendo Developer Portal FAQ; IARC FAQ; PEGI — How we rate games; IARC milestones
What this means in practice
You cannot fill in the official IARC form today from this website, and you should not invent answers in advance as if they were a submitted rating. You can, and should, walk through the kinds of questions you will be asked, with Super Tank Battles in mind, so that your answers are complete and accurate when the real form appears inside Nintendo’s submission flow.
PEGI labels, in PEGI’s own words
PEGI uses age bands 3, 7, 12, 16 and 18. From What do the labels mean?:
- PEGI 3 — considered suitable for all age groups. Should not contain sounds or pictures likely to frighten young children. A very mild form of violence in a comical or childlike setting is acceptable. No bad language.
- PEGI 7 — scenes or sounds that can possibly frighten younger children. Very mild violence (implied, non-detailed, or non-realistic) is acceptable.
- PEGI 12 — slightly more graphic violence towards fantasy characters, or non-realistic violence towards human-like characters. Sexual innuendo or posturing may be present; bad language must be mild.
- PEGI 16 — violence (or sexual activity) that looks as would be expected in real life. Bad language can be more extreme; tobacco, alcohol or illegal drugs can also be present.
- PEGI 18 — gross violence, apparently motiveless killing, or violence towards defenceless characters, among other adult content.
Descriptors can include violence, bad language, fear/horror, gambling, sex, drugs, discrimination, and interactive risks such as in-game purchases and unrestricted communication. PEGI notes that, since June 2026, some in-game purchase and “pressure to play” features affect the age rating. If Super Tank Battles has no chat, no real-money purchases and no loot boxes, those descriptors should not be relevant — but you must answer the official questionnaire as it stands at submission, not from memory of this summary.
Source: PEGI — What do the labels mean?
A cautious reading for this game
Super Tank Battles is an artillery game in which tanks shoot at one another and terrain is destroyed. That is violence, even if it is stylised. Whether it is closer to “very mild / non-realistic” or to something stronger depends on the finished art, animation, sound, language and tone. This course will not predict an official PEGI or ESRB rating. Answer the questionnaire truthfully against the finished build, and do not try to “aim” at a number.
Physical copies and Japan are different
IARC ratings are for participating digital storefronts. IARC itself explains that the automated, post-release model is designed for digital goods, and that IARC ratings generally cannot be used on physical products in the same way. A boxed or cartridge release, or some territories such as a traditional CERO process in Japan, can mean a different, sometimes paid, path. Nintendo’s public FAQ confirms the portal can also be used if you are interested in retail publishing, but it does not document those extra rating fees on the FAQ. If you ever want a physical edition, get current instructions from Nintendo and the relevant rating board rather than assuming the free IARC path covers a box in a shop.
The Games Rating Authority notes that, in the UK, the Video Recordings Act makes it illegal to supply PEGI 12, 16 or 18 games in physical form to anyone under those ages, and that this Act “doesn’t currently apply to online games” in the same way. Parental controls still matter. This is background, not a reason to treat a digital rating casually.
Source: Games Rating Authority — PEGI Ratings