Why MangaGamer Bothered Submitting An Adult Visual Novel To The ESRB


Visual novel publisher MangaGamer have gone to the trouble of getting an upcoming erotic visual novel rated by the ESRB. ef: a fairy tale of two, a visual novel developed by Japanese developer minori, was submitted to the ESRB for certification and, to nobody’s surprise, has come back with an “AO” (Adults Only) rating.


This is completely normal, of course—ef has rather explicit sexual content and MangaGamer knew exactly what the rating was going to be, before they even submitted the game. What is surprising is that MangaGamer bothered to file for an ESRB rating at all, given that they don’t really need one. Most of the company’s games (all of which are on PC) are sold through their online store or other specialist retailers. On the rare occasion, they’re sold directly to fans at anime conventions. Even Valve’s Steam service—which currently hosts two of MangaGamer’s titles—does not require that a game be ESRB-certified.


“The main reason was for us to be able to release ef in hardcopy form,” MangaGamer’s Head Translator, John Pickett, said to Siliconera. “As minori previously mentioned in their message for Western fans, they as a company are concerned about what is acceptable for publishing and who will bear the responsibility if a given title proves otherwise.”


The message being referred to is the one on MangaGamer’s development blog. In explaining their stance on being responsible for the games you release, minori provided the following explanation:


“In the domestic Japanese market, our products undergo inspection by EOCS (The Ethics Organization of Computer Software), and the business known as minori bears responsibility. This is because they establish a standard for what level of expression is considered to be socially acceptable within our society’s constantly changing values, and passing inspection means that we have abided by them. In contrast, this release is not undergoing inspection by any organizations such as the ESRB nor the PEGI. When we discussed this issue with MangaGamer.com, MangaGamer.com made it clear that they will be the ones who will preside over ethical issues and bear responsibility. In other words, the release of this English version was possible because it was made clear who would accept social responsibility for it.”


“With digital sales, it’s very easy to track and record who bought a copy of their game, and point out whether or not the copy was indeed sold to a person,” Pickett said to me. “Hardcopies, however, are much harder to track due to wholesale and storefront sales at conventions and more.”


“Once we print hardcopies, it becomes impossible to say a person couldn’t or didn’t obtain that hardcopy through someone else, so it’s important to have a rating that says, ‘this is okay to sell in this nation’. By having it reviewed and rated, we can now point and say the ESRB considers it appropriate for sale in the USA.


“What this meant, is that in order for minori to feel comfortable about releasing ef in hardcopy form, they wanted to make sure the game was rated and approved by an official ratings board, in this case the ESRB. It took us a while to navigate all the steps to get ef rated, but we’re definitely happy to present this Limited Edition hardcopy release.”


This isn’t the first time in recent years that a visual novel publisher has felt the need to do things “by the book”. When JAST USA published Steins;Gate in English, they, too, reached out to the ESRB for a rating (it got an M), while MoeNovel’s If My Heart Had Wings is another example of an ESRB-rated visual novel on PC.

Ishaan Sahdev
Ishaan specializes in game design/sales analysis. He's the former managing editor of Siliconera and wrote the book "The Legend of Zelda - A Complete Development History". He also used to moonlight as a professional manga editor. These days, his day job has nothing to do with games, but the two inform each other nonetheless.