Games which currently warrant a PEGI 12+ rating feature content that is in line with other media aimed at that age group which doesn’t carry statutory ratings (e.g. books, comics, board games, etc.). Content which would warrant a BBFC 12 or 12A rating in film (e.g. the scenes of sadistic violence in The Dark Knight) routinely get a PEGI 16+ and/or BBFC 15 or 18 in games.

It comes back to a problem that is present throughout the report (and the consultation questions beforehand) – the presumption that age-inappropriate content poses a quantifiable ‘risk’ to children. Making a generalised case for ‘risk’ is fairly shaky for 15 and 18 rated media (with the exception of extreme edge cases), but becomes practically meaningless at the 12 and below bracket.

The idea of a child of any age being ‘harmed’ by a game like Guitar Hero III or Zelda:TP (to pick two fairly recent 12+ ratings), and the sale of such a game resulting in a criminal prosecution being useful or helpful to the public is absurd.

There are four-and-a-bit pages of reasoning in there, from section 7.30 on page 167 through to 7.50 on 172. It makes for far more interesting discussion.