Classification (Publications, Films and Computer Games) (Consumer Advice Terms) Determination 2025

The Determination’s central concept is a closed list of consumer advice terms that must be used when determining consumer advice under the Act. The operative legal basis is paragraph 12A(1)(a) of the Act (referenced in ss 6-7). Two separate schedules enumerate consumer advice terms for films and for computer games; the lists are structured by classification categories (G, PG, M, MA 15+, R 18+) and by classifiable elements (for example, Themes, Violence, Language, Drug use, Nudity, Sex). Schedule 2 for computer games includes an additional classifiable element reflecting modern interactive features: Online interactivity and in‑game purchases (Schedule 2, item 6).

Key structural features of the lists:

• Categorisation by classification level: Each schedule groups permissible consumer advice terms by the classification level to which the media may be assigned (e.g. Schedule 1, Table 3,M; Schedule 2, Table 5,R 18+). The Determination therefore ties the vocabulary available for consumer advice to the statutory classification categories used across the Act.
• Granularity of intensity: For many classifiable elements, the lists use a graduated intensity scale: Very mild, Mild, Mature, Strong, High impact. That scale appears across various elements (Themes, Violence, Language, Drug use, Nudity, Sex) in both schedules. For example, Schedule 1 Table 1 lists “Very mild violence” for G, whereas Schedule 1 Table 5 lists “High impact violence” for R 18+.
• Element‑specific entries: The schedules list specific phrases that reflect both content types and particular contexts. Examples include “bullying themes”, “family violence”, “references to sexual violence”, “suicide references”, “medical procedures”, and in the computer games schedule “chance‑based in‑game purchases” and “simulated gambling”.
• Applicability to online features: Schedule 2 explicitly covers “Online interactivity and in‑game purchases” and provides a table (Table 6) listing consumer advice such as “Online interactivity”, “Online interactivity and chat”, and “In‑game purchases”. Those terms may be applied across the classification categories where appropriate (Schedule 2, item 6).

Definitions and cross‑references: The Determination relies on statutory definitions in the Act. Section 5 of the Determination notes that a number of expressions used in the instrument are defined in section 5 of the Act (including classifiable element, classified, Code, film). It also notes that the expression computer game is defined in section 5A of the Act (see s 5 of the Determination). The Determination also identifies that the classification guidelines made under section 12 of the Act are relevant for applying the lists (s 5, definition of classification guidelines).

Procedurally, this is a non‑legislative standardising instrument: it does not purport to change definitions or classification boundaries but prescribes the vocabulary the Board will use when forming consumer advice. The lists thus operate as mandatory options for consumer advice in classification determinations from the commencement date onward (ss 6-8).

The instrument’s immediate legal effect is directed at the process of classification under the Act, so the principal actors affected are those involved in classification decisions and those who apply for classification.

• Classification Board and decision makers: The Determination instructs that the Board must use the listed consumer advice terms for the purposes of paragraph 12A(1)(a) of the Act (ss 6-7). Therefore, classifiers and administrative staff who prepare classification decisions will apply these prescribed terms when determining and recording consumer advice for films and computer games classified on or after the commencement date.
• Applicants for classification: The Determination explicitly applies to “applications for classification for a film or computer [game] made on and from the commencement date” (s 8(2)). Producers, distributors, publishers, and other parties that file applications for classification for films or computer games after commencement will be required to have their content assessed against the lists in Schedule 1 or Schedule 2. Practically, applicants will need to be prepared to see consumer advice drawn only from these lists attached to any eventual classification decision.
• Items classified on or after commencement: The lists govern the consumer advice attached to films and computer games classified on and from the commencement date (s 8(1)). Content already classified before commencement is excluded by the phrasing of s 8. Distributors and retailers of newly classified films or computer games will therefore receive consumer advice framed in the Determination’s terms for affected items.
• Consumers: While the Determination does not itself mandate how consumer advice must be displayed or communicated, the consumer advice the Board provides forms part of classification decisions and so will inform consumers (through whatever display or publication regime applies under the Act or the Code) about content features. Users of classification data , parents, educators, platform operators, storefronts and aggregation services , will receive consumer advice framed in the prescribed vocabulary.
• Intermediaries and platforms: For computer games in particular, the inclusion of online interactivity, in‑game purchases and chance‑based purchase terminology will be relevant to publishers and digital platform operators who manage storefront information, previews, and parental controls. The Determination does not set obligations for platforms, but the consumer advice it produces will be their raw input for content labelling and metadata.

Other affected parties: The Determination replaces the 2024 Consumer Advice Terms Determination (s 4). Organisations with compliance processes or documentation referencing the 2024 lists will need to update processes on or before the Determination’s commencement date. The Board’s staff who produce classification outputs, and any third‑party systems that ingest classification metadata, will need to map to the 2025 term set rather than the 2024 set once the Determination commences.

Note on scope: The instrument is limited to consumer advice terms. It does not purport to change classification categories themselves, nor does it define display obligations or enforcement mechanisms within its text. Those aspects remain within the Act, the Code and associated guidelines referred to in the Determination (s 5).

The Determination creates a prescriptive framework for the vocabulary used in consumer advice; it establishes the Board’s mandated list for use when determining consumer advice under the Act (ss 6-7). The text itself describes the following duties and rights, as they are contained or implied by the instrument.

Duties imposed by the instrument

• Duty to use the listed terms in consumer advice determinations: For the purposes of paragraph 12A(1)(a) of the Act, the Board must use the list in Schedule 1 for films (s 6) and Schedule 2 for computer games (s 7). That is the instrument’s primary operational command. The Determination thereby constrains the set of terms that may be used in consumer advice for items classified on or after the commencement date.
• Application timing: The lists are to be used for classification determinations and classification applications that occur on and from the commencement date (s 8). Practically, classifiers must apply the new lists for relevant items from that date forward.
• Reliance on statutory definitions and guidelines: The Determination directs users to the Act for definitions (s 5) and to the classification guidelines (s 5). Those cross‑references create an implicit duty to consult the Act’s definitions (for classifiable element, film, computer game etc.) and the classification guidelines under section 12 when applying the consumer advice lists.

Rights and limits embodied in the instrument

• No creation of new rights of appeal or enforcement remedies within the Determination: The instrument does not itself create rights of appeal or new enforcement mechanisms. Any rights to challenge classification decisions or to seek review remain the province of the Act and any procedural law established elsewhere. The Determination confines itself to prescribing terms.
• Board’s discretion constrained but not eliminated: The instrument prescribes the vocabulary available to the Board for consumer advice, which constrains how the Board characterises content in consumer advice statements. The Determination does not purport to dictate how the Board should weight different classifiable elements in reaching a classification or how it should decide a classification category. It therefore limits the Board’s verbal choices for consumer advice while leaving adjudicative discretion about classification outcomes and the application of guidelines intact.

Operational consequences for applicants and distributors

• Applicants can expect consumer advice to be drawn only from the listed terms for content classified on or after commencement (s 8). That affects the predictability of the consumer advice attached to classification outcomes.
• The Determination does not state obligations to display consumer advice on packaging, advertising or online storefronts. Any obligations to publish or display consumer advice remain governed by the Act, the Code and the classification guidelines referred to in s 5. Practitioners should therefore distinguish between the Determination’s vocabulary constraint and any separate statutory or regulatory display requirements.

Procedural compliance points

• The Board must align its classification outputs to the Determination’s lists for the relevant items. Given the cross‑reference to classification guidelines (s 5), classifiers must ensure that consumer advice phrasing chosen from the lists fits with the Board’s guideline‑based reasoning for a classification.

In short, the Determination imposes a binding vocabulary duty on classifiers (and, indirectly, creates predictability for applicants and downstream users) while leaving adjudicative classification discretion and enforcement mechanisms to the Act and Code.

The Determination itself does not create any penalties, criminal offences or specified enforcement mechanisms. Its text is limited to prescribing consumer advice terminology (ss 6-7), setting its application (s 8), and repealing the earlier Determination (s 4). There is no provision within this instrument that creates compliance penalties, fines, criminal liability or civil remedies.

Enforcement and penalties therefore remain matters for the Act and the Code, not this Determination. The instrument is created under section 12A of the Act (s 3), and it incorporates by reference the Act’s definitions and the classification guidelines (s 5); any enforcement of classification obligations, sanctions for non‑compliance with classification or display requirements, or review rights would be governed by those separate statutory provisions and the administrative procedures under the Act. The Determination does not purport to alter those mechanisms.

Practical points for practitioners and affected parties:

• If a person or entity is concerned about a classification decision or the consumer advice attached to it, any available legal challenges, merits review processes, or complaints mechanisms must be sought under the Act, the Code or administrative law avenues , not under the Determination itself. The Determination does not specify appeal routes or remedies.
• Because the Determination constrains the vocabulary used for consumer advice but does not impose display obligations within its text, potential non‑compliance with display or labelling requirements (if any exist elsewhere in the Act or Code) would be addressed under those provisions rather than under the Determination.
• The lack of penalties in the Determination means that disputes about the adequacy, accuracy, or appropriateness of consumer advice terms will be procedural or substantive classification issues. Any sanction for misuse of classification marks or misrepresentation of a classified item would need to be located in the Act or other regulation.

The instrument’s silence on penalties implies two things: first, the Determination functions as an administrative specification rather than a punitive regime; second, to determine enforcement risk or sanction exposure related to classification and consumer advice one must consult the Act, the Code and any other statutory instruments that set out offences or administrative penalties. The Determination itself does not provide those details.

The Determination is expressly a subordinate instrument operating under the Act. The instrument’s text cross‑references and relies on defined terms and guidelines within the Act: it is made under s 12A of the Act (s 3), notes that expressions used in the instrument are defined in section 5 of the Act (s 5, Note 1), and points to the definition of computer game in section 5A of the Act (s 5, Note 2). It also identifies the classification guidelines determined under section 12 of the Act as relevant (s 5). Those cross‑references define the Determination’s legal boundaries.

Direct interactions identified in the instrument:

• Act as parent statute: The Determination fulfills a statutory function under section 12A(1)(a) of the Act by determining the list of consumer advice terms for use in classification determinations (ss 6-7). Consequently, the Determination’s terms are operationalised only through the Act’s classification apparatus. Any interpretive questions about the precise meaning of classifiable elements or the scope of “consumer advice” are to be addressed by reference to the Act and the classification guidelines under section 12 (s 5).
• Classification guidelines: The instrument directs classifiers to use the classification guidelines (s 5). The guidelines, made under section 12 of the Act, are the mechanism through which the Board interprets how classifiable elements and consumer advice interact with classification decisions. The Determination does not replace or alter those guidelines; it provides the permitted vocabulary to be used within that framework.
• Repeal of prior instrument: The Determination repeals the Classification (Publications, Films and Computer Games) (Consumer Advice Terms) Determination 2024 (s 4). That repeal means that the 2024 term set is withdrawn and replaced by the 2025 lists from the Determination’s commencement date. Systems and compliance processes referencing the 2024 list will need to be updated to align with the 2025 lists where the Act requires use of the Determination’s vocabulary.
• Definitions in the Act: The Determination relies on the statutory definitions in the Act for terms it uses. For instance, the instrument notes that “classifiable element,” “classified,” “Code,” “film” are defined in section 5 of the Act, and “computer game” is defined in section 5A. Those statutory definitions will determine the scope of the classifiable elements listed in the schedules (s 5).

Interactions not addressed within the Determination:

• Display, labelling and commercial obligations: The Determination prescribes the terms to be used for consumer advice but does not state how consumer advice must be displayed, incorporated into consumer products, or used in advertising. Any statutory obligations to display classifications or consumer advice, or to refrain from misrepresenting classifications, are matters for the Act and the Code; the Determination does not itself create or modify those obligations.
• Civil liability and intellectual property: The Determination does not comment on civil liability issues such as misleading or deceptive conduct or intellectual property rights. Any interface with consumer protection, advertising law, or contractual obligations will be determined by those respective statutes and common law.
• Platform and industry regulation: For computer games, the inclusion of terms related to online interactivity and in‑game purchases will interact operationally with platform metadata and age‑rating systems. The Determination does not regulate platforms directly; any legal obligations platforms have to display or respect classifications will still derive from other legal instruments or contractual arrangements.

In short, the Determination is an instrument that slots into the Act’s classification machinery. It does not replace the Act, the Code, the classification guidelines, or other regulatory instruments; it specifies the vocabulary the Board must use in consumer advice determinations while leaving broader legal obligations and enforcement to the statutory framework.

The Determination records a discrete amendment step: it repeals the Classification (Publications, Films and Computer Games) (Consumer Advice Terms) Determination 2024 (s 4). The 2025 instrument therefore replaces the prior year’s list of consumer advice terms. The Determination itself is dated 10 December 2025 and signed on behalf of the Classification Board by the Director, Classification Board (cover note and signature block).

There is no further amendment history recorded within the text of the instrument. The instrument contains the following temporal mechanics:

• Registration to commencement lag: It commences the day after the end of the period of three months beginning on the day it is registered (s 2). That timing introduces a defined window between registration and legal effect during which affected parties can update processes, provided the registration date is known.
• Application period: The Determination applies to classifications and classification applications occurring on and from the commencement date (s 8). That establishes a bright‑line temporal boundary: items classified before commencement are outside the Determination’s reach, and items classified or applied for on/after commencement are within it.

The instrument does not record any prior amendments to itself nor does it set out an anticipated amendment timetable. Because it repeals the 2024 Determination, the instrument is a successor specification; subsequent changes to the consumer advice vocabulary would be effected by a further Determination under section 12A of the Act.

Practitioners should note the following practical amendment‑related points arising from the text:

• Transition: The explicit repeal of the 2024 Determination means that from the commencement date onward the 2025 list is the authoritative set. Stakeholders should ensure that any reference data, compliance checklists, classification submission templates, and metadata ingestion systems are updated at or before the commencement date.
• Administrative notification: The Determination itself does not specify transitional arrangements for items straddling the commencement date (for example, items submitted shortly before commencement but classified after). The operative wording in s 8(2) states the lists apply to “applications for classification for a film or computer [game] made on and from the commencement date,” which implies that applications lodged before commencement are not captured by the Determination. Practitioners should therefore verify timing when preparing submissions.
• Repeal effect: Because the 2024 Determination is expressly repealed, any consumer advice wording previously authorised only by the 2024 list will no longer be authorised after commencement. Users of classification metadata must map older terminologies to the new lists where necessary for continuity.

No other instruments, amendments or legislative changes are recorded within the Determination’s text.

The Determination does not record any litigation history. It does not cite cases, judicial decisions, references to administrative reviews or prior litigation involving the consumer advice terms. The instrument is a technical administrative determination and contains no statement about challenges, appeals or disputes arising from its contents.

Practical implications of the instrument’s silence on litigation:

• No precedent provided: There is no internal case law or recorded disputes in the Determination to guide interpretation of specific phrases in the schedules. Interpretive questions about ambiguous phrases or the way terms should be applied in borderline cases will fall to the Board, the classification guidelines, and, ultimately, courts or tribunals if any party initiates review or litigation under the Act.
• Review mechanisms remain in the Act: Because the Determination does not set out appeal processes or adjudicative protocols, any legal review of a classification decision that incorporates these consumer advice terms would proceed under the Act’s review and appeal provisions and general administrative law principles, not under the Determination itself. Practitioners seeking to challenge a classification should therefore consult the Act and the Code for available remedies.
• Potential future litigation topics: While the Determination does not identify contested areas, the inclusion of interactive‑economy terminology in Schedule 2 (for example, “chance‑based in‑game purchases”, “simulated gambling”) suggests potential areas where future disputes could arise about whether a particular game feature sufficiently fits a listed term. That possibility is not stated in the Determination; it is an operational observation based on the content of the lists. Any precise dispute over term application would be resolved by the Board’s application of the classification guidelines and, if contested, by available review routes under the Act.

In short, the Determination provides no litigation history and no guidance on prior judicial interpretation of its terms. Practitioners should treat the instrument as authoritative for vocabulary and look to the Act and classification guidelines , and to any subsequent administrative decisions or judicial rulings , for interpretive precedents.

This Determination is compact and prescriptive, but several practical pitfalls and sources of ambiguity arise directly from the text. These are matters to watch for when advising clients, preparing classification submissions, or integrating classification metadata into systems.

1. Commencement timing and application window

• The Determination commences the day after the end of the period of three months beginning on the day it is registered (s 2). That creates a discrete lead time between registration and legal effect. Misreading or mis‑calculating the registration date could lead to using the wrong set of terms for an application or a classification decision. Note also s 8’s bifurcated application: it applies to (a) items classified on and from the commencement date and (b) to applications made on and from the commencement date. That phrasing suggests that applications lodged before commencement are not captured, even if classified after commencement; practitioners should therefore confirm timing precisely rather than assume “classified after commencement” alone controls.

2. Replacement of 2024 Determination

• The 2025 Determination expressly repeals the 2024 Determination (s 4). Any processes or metadata mapped to the 2024 lists must be updated. Failure to migrate could produce inconsistent consumer advice outputs after the commencement date.

3. Vocabulary formatting and possible parsing ambiguities

• The schedules present consumer advice phrases concatenated together in many cells (for example, Schedule 1 Table 1 lists “Very mild themesVery mild bullying themesVery mild crude humourVery mild threatVery mild scary scenes”). That presentation requires classifiers to parse contiguous text into distinct consumer advice phrases. Systems that ingest lists mechanically might mis‑parse entries if they expect commas or line breaks. Practitioners should ensure their data models map to the intended discrete phrases (for example, “Very mild themes”, “Very mild bullying themes”, “Very mild crude humour”, etc.).

4. Overlapping or similar terms across categories

• Several terms recur across classification bands with only intensity adjectives changing (Very mild, Mild, Mature, Strong, High impact). Determining when a content feature merits “Mature themes” versus “Strong themes” is a matter for the Board and the classification guidelines (see s 5). The Determination does not set thresholds. That leaves scope for discretionary variation in how the Board describes consumer advice, which in turn may affect predictability for applicants.

5. Newer interactive economy terms in Schedule 2

• The computer games schedule includes “chance‑based in‑game purchases” and “simulated gambling” (Schedule 2 Tables 3-5 and Table 6). The Determination places these entries as themes or online interactivity elements rather than as a separate statutory classification category. The practical consequence is that classifiers will attach these labels as consumer advice rather than as a classification ground; the instrument does not define these terms. Disputes could arise over whether a feature qualifies as “chance‑based” or “simulated gambling”. Again, resolving such disputes will depend on the Act’s definitions and the classification guidelines.

6. No display obligations in the Determination

• The instrument prescribes the vocabulary but does not state how consumer advice must be communicated to the public, displayed on packaging, included in metadata feeds, or represented in online storefronts. Any obligations to display or label remain in the Act or Code. Relying parties must not assume the Determination imposes a duty to publish or to alter packaging.

7. Narrow scope: consumer advice terms only

• This instrument is purposely narrow: it determines consumer advice terms only. It does not change classification categories, definitions in the Act, the Code, or penalties. Parties seeking broader changes will not find them here. Misconstruing the Determination as substantive change to classification thresholds or legal definitions would be an error.

8. Consistency across media

• While Schedules 1 and 2 mirror each other in structure, there are small differences in content (for example, Schedule 2’s explicit referencing of gambling themes and chance‑based purchases). Practitioners should not assume identical treatment across film and game media when mapping consumer advice in multi‑format releases.

9. Administrative downstream effects

• Systems and third‑party data consumers that automatically ingest classification metadata need to be prepared to accept the new vocabulary. Automated mapping between legacy terminology and the 2025 terms may require attention to ensure continuity for consumers and compliance reporting.

Those “gotchas” arise directly from the Determination’s text and structure. They highlight operational and interpretive issues that practitioners and affected parties will need to manage when the Determination takes effect.

Compliance with this Determination is primarily procedural: the Board must use the listed consumer advice terms when determining consumer advice for films and computer games classified on or after the commencement date, and applicants must expect consumer advice to be drawn from those lists for applications made on or after commencement (ss 6-8). The Determination does not itself create display obligations or penalties; those remain matters for the Act and the Code (s 5). Practical compliance steps follow from the instrument’s requirements and structure.

For Classification Board staff and classifiers

• Update internal classification templates and decision records to the 2025 term set. Replace any references to the repealed 2024 Determination with the 2025 Determination in procedures and data models (s 4).
• Ensure that classification reports and public outputs use only the permitted phrasing from Schedules 1 and 2 when composing consumer advice text (ss 6-7). Do not invent or use terms outside the lists when labelling consumer advice.
• Consult the Act’s definitions (s 5) and the classification guidelines (s 5) when applying phrases, particularly where the same substantive label (for example “self‑harm” or “suicide scenes”) appears across different intensity levels.
• Address formatting differences: ensure that lists are parsed into discrete phrases where the schedule text appears concatenated. Implement a controlled vocabulary file (for example CSV or JSON) derived from the instrument that lists each permitted phrase on a single line to avoid parsing errors.

For applicants (producers, publishers, distributors)

• Time submissions to the classification regime with awareness of the Determination’s commencement rule (s 2 and s 8). If the application is to be lodged on or after the commencement date, expect the Board to use the 2025 lists; if lodged before the commencement date, the 2025 Determination may not apply (see s 8).
• When preparing classification submissions, tag or annotate content elements against the Determination’s discrete terms where applicable (for example, identify whether a game contains “chance‑based in‑game purchases” or merely “in‑game purchases”). This speeds assessment and aligns applicant expectations with the vocabulary the Board must use.
• Update packaging, storefront metadata and marketing processes to account for the consumer advice language likely to be produced by the Board. Even though the Determination does not mandate display, the consumer advice it produces is the source material for labelling and for age‑rating metadata on platforms.
• Maintain records showing how content maps to the Determination’s listed terms. If an applicant disagrees with a classification or a consumer advice wording, a clear audit trail of how content features correspond to listed terms will assist in any review or communication with the Board.

For digital platforms and storefront operators

• Prepare to ingest classification metadata that uses the 2025 vocabulary. Update metadata mapping tables and UI label libraries to include the new phrases from Schedule 2, including online interactivity entries (“Online interactivity and chat”, “In‑game purchases”, “chance‑based in‑game purchases”, “simulated gambling”).
• Where platforms provide parental controls based on content flags, ensure those controls understand the intensity gradations (Very mild, Mild, Mature, Strong, High impact) so that platform rules act consistently with the Board’s consumer advice.

For compliance officers and counsel

• Do not assume the Determination creates display obligations or enforceable penalties; consult the Act and the Code for those matters, since the Determination is limited to determining the list of consumer advice terms (s 5).
• Reconcile legacy classification data with the 2025 list prior to the commencement date to avoid inconsistent consumer advice presentation. Where necessary, prepare mappings from 2024 terms to 2025 terms with documented assumptions.
• Advise clients to be precise about timing: applications lodged shortly before the commencement date may remain governed by the prior Determination. Check the registration and commencement dates to make accurate recommendations.
• If a client expects a classification decision to hinge on the new consumer advice vocabulary (for example, where “chance‑based in‑game purchases” could materially affect consumer response), build record‑level arguments in submissions referencing the Act’s definitions and the classification guidelines, since the Determination itself does not supply definitions or thresholds for ambiguous phrases.

Operational checklist

1. Identify all pending and planned classification applications and map them to the Determination’s commencement date (s 2; s 8).
2. Replace any 2024 Determination references in internal procedures with the 2025 Determination (s 4).
3. Implement a controlled vocabulary file for the 2025 lists, ensuring discrete parsing of concatenated phrases from the schedules (Schedules 1 and 2).
4. Train classification officers, submitters and metadata engineers on the intensity gradations and on the presence of interactive economy terms in Schedule 2.
5. Document content mappings to listed terms for audit trails, internal review and potential administrative review.

In summary, compliance centres on timing, vocabulary alignment and careful record‑keeping. The Determination prescribes what the Board may say in consumer advice; affected parties must anticipate and integrate that prescribed language into submissions, metadata and consumer‑facing materials while relying on the Act and the classification guidelines for thresholds, definitions and enforcement mechanisms.