New Mobile Apps Rating System for Kids
By Danica Mathes
A new age-based ratings system for mobile software applications for children launched on November 29, 2011. The rating system is governed by a new partnership between the Entertainment Software Ratings Board (ESRB) and CTIA-The Wireless Association®.
The CTIA Mobile Application Rating System with ESRB
The CTIA Mobile Application Rating System with ESRB is an extension of CTIA’s 2010 Guidelines for Application Content Classification and Ratings, which was developed with a number of organizations, including the six founding storefronts. The goal of the initiative is to support the commitment to provide consumers with the information and tools they need to make informed choices when accessing applications using wireless devices, such as reliable information about the age-appropriateness of applications.
The system will utilize familiar age-rating icons that ESRB introduced for computer and video games in 1994. Apps will fall into six categories: EC for Early Childhood (3 and older), E for Everyone (6 and older), E10+ for Everyone 10+, T for Teen (13 and older), M for Mature (17 and older), and AO for Adults Only (18 and older).
Participating Storefronts
As of the program launch, six mobile app storefronts (AT&T, Microsoft, Sprint, T-Mobile USA, U.S. Cellular and Verizon Wireless) have signed on to voluntarily support the ratings system as part of their application submission (or onboarding) process. Currently, Apple and Google have their own app rating systems and are not participating in the CTIA-ESRB program. The new rating system is currently operational. However, as technologies and buildout schedules differ by each storefront, full implementation will vary. Each storefront will make its own announcement regarding when the rating system will be available for their customers.
Once a storefront begins supporting the CTIA Mobile Application Rating System as part of its onboarding process, developers will be asked to rate new applications added to that storefront. Each storefront will decide on an individual basis whether to require all applications to be rated and
if certain categories of applications, such as news or e-readers, will be exempt from the rating system.
App Developer Submission Process
When submitting their applications to participating storefronts, developers will be asked to complete a detailed yet quick multiple choice form about their application’s content. This online questionnaire was devised by ESRB (based on its experience of assigning content ratings for more than 17 years) and covers the content areas that are typically addressed by age ratings, including violence, sexual or suggestive content, nudity, language, substances, etc., as well as contextual elements such as setting (fantasy vs. realistic), the nature of depictions (stylized vs. photo-realistic) and
the user’s perspective (up close vs. distant). Other elements are also taken into consideration, such as a minimum age requirement, the exchange of user-generated content, the sharing of a user’s location with other users of the application and the collection and sharing of personal information with third parties.
Developers submitting applications with an 18+ age requirement must further specify the reason for the requirement. Any answer other than enables commercial transactions” will generate an Adults Only (AO) rating. However, even those applications may be eligible for a less restrictive rating than Adults Only if, for example, they provide controls allowing an account-holder to block access to sexually explicit content.
Once the developer completes all answers to these questions, the application’s rating will be provided within seconds. If a developer has answered all questions fully but still believes the rating assigned is not appropriate, they may appeal the rating to the ESRB. Consumers are also encouraged to contact ESRB if they believe an app contains questionable content or the rating is not appropriate. If an inappropriate rating
is found to have been assigned, ESRB will promptly adjust the rating and will notify the developer and the storefront(s) that have the application to ensure consumers have reliable information.
There is no charge to submit an application or obtain a rating. Furthermore, applications that have already been rated by one participating storefront will not need to be resubmitted. When a developer submits an application, it will be assigned a unique rating certification code that can be used when the application is subsequently submitted to another participating storefront.
Ratings do not have an expiration date or a renewal requirement. However, if subsequent updates to an app modify its content in a way that may affect its rating, it should be resubmitted.
As mobile apps are a huge segment of the entertainment and technology industries, this new age-rating system should be of crucial interest to app developers and consumers alike.
Danica L. Mathes, of counsel with Bell Nunnally & Martin LLP, handles intellectual property, new media and entertainment matters. She can be reached at danicam@bellnunnally.com.
