Are skill games banned by MP 1.394/2026?

No prohibition has been identified under MP 1.394/2026 for skill games as of 4 October 2026, but there is no statutory safe harbour. They remain subject to LCP Art. 50, which defines a game of chance as one where gain and loss depend exclusively or predominantly on luck, and to consumer, child-protection, payment and store rules. Confirm with Brazilian counsel.

What is the legal test for a skill game in Brazil?

The statutory wording is LCP Art. 50 §3(a): a game of chance is one "in which gain and loss depend exclusively or predominantly on luck". The law sets no percentage or factor list. Engineering checklists help reduce product risk but are not legal tests.

Are PvP duels treated differently from tournaments?

Both are tested under the same rules. Duels raise extra questions about matchmaking quality, whether the operator ever holds a position, and whether LCP Art. 50 §3(c), which covers bets on sports competitions, could be read to apply. Counsel should review the specific format.

Do the BCB payment-blocking rules cover skill games?

Resolutions BCB 595, 596 and 597 of 30 September 2026 target transactions destined for fixed-odds betting and do not name skill games. Payment institutions still apply their own risk policies, so a skill product should be described accurately and reviewed with each partner.

What does PL 5477/2026 mean for skill games?

It is a bill, not law. Its summary says it would amend Decree-Law 3.688/1941 to delimit the scope of the misdemeanour of exploiting games of chance, which is the provision skill games are tested under. Track its text and stage before committing to a launch.

Can we reuse our betting platform for a skill product?

Usually the PAM, KYC, responsible-play tooling and analytics infrastructure carry over. The wallet must be rebuilt around escrow, game logic moves to an authoritative server, and the odds engine and RNG integrations are removed. Brazilian player data from the betting product stays in its compliance archive.

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