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Brazil opens FUNCINES audiovisual funds to games

Hey, everyone!


On Thursday, May 7, 2026, Brazil's film and audiovisual regulatory agency ANCINE (Agência Nacional do Cinema) approved Instrução Normativa nº 176, modernizing the rules for FUNCINES, Brazil's audiovisual investment funds. For the first time, independent Brazilian electronic games are listed by name as projects eligible for FUNCINES financing.

As president of ASCJogos and co-founder of Plot Interactive, I've been tracking this conversation for years alongside Abragames and other regional associations. Let me unpack this milestone: what it is, what changes, and why it matters for our ecosystem.


This post covers:

  • What Instrução Normativa nº 176 is and why it's a turning point

  • What FUNCINES are and why this instrument differs from the grant programs the industry already knows

  • Four concrete wins the new regulation brings to Brazilian game studios

  • How we got here, from the Marco Legal dos Games (Brazil's federal Games Legal Framework) to IN 176

  • What's next in the regulatory calendar


If you follow or work in the Brazilian games sector, this change deserves your attention.


➔ Brazilian government context (for international readers)

A quick primer for readers outside Brazil. Brazil is a federation with three levels of government: federal (national), state (26 states plus the Federal District), and municipal. ANCINE is a federal regulatory agency, attached to the Ministry of Culture, that oversees the audiovisual sector across the entire country. The agency issues instruções normativas (technical regulations) that detail how broader laws apply in practice. An ANCINE IN sits one level below the law it implements: the law sets the principle, the IN sets the rules.

Two other terms worth knowing. The Lei Rouanet (Brazil's federal cultural-incentive law) lets companies and individuals receive tax credits for sponsoring cultural projects, including some game projects since the Marco Legal dos Games took effect. The Lei do Audiovisual (Brazil's federal audiovisual incentive law, Lei 8.685/1993) is the legal foundation under which FUNCINES were created. These two laws plus the new Marco Legal dos Games (Law 14.852/2024) are the three pillars that intersect in the IN 176 story.


➔ What changes with Instrução Normativa nº 176/2026

IN 176 revokes the previous IN 80 and modernizes the regulatory framework for FUNCINES. The change that directly affects our sector is simple to state and enormous in its consequences: independent Brazilian electronic games are now, in express text, listed as projects eligible for FUNCINES financing. According to ANCINE, the inclusion of games received "broad favorable support" during the public consultation phase, a strong indicator that the broader Brazilian audiovisual sector already sees games as part of the same ecosystem.

The IN also brings a series of structural changes to FUNCINES as an instrument, which I'll detail below. But the starting point is this: what was previously an omission (or at best, an indirect and stalled eligibility) became explicit inclusion.


➔ FUNCINES in 30 seconds: the instrument behind the news

For readers unfamiliar with Brazil's audiovisual sector, a quick explanation. FUNCINES (Fundos de Financiamento da Indústria Cinematográfica Nacional) are private investment funds, with tax incentives written into law, that channel private capital into Brazilian audiovisual projects. An investor contributes capital, receives the corresponding tax incentive, and gets a financial return if the financed project succeeds.

This logic is different from what most Brazilian game studios are familiar with. The funding instruments our sector uses today (FAPESC, FCC, Lei Rouanet, BNDES Garagem, Lei Paulo Gustavo, FSA via grants, etc.) are mostly based on non-reimbursable competitive grants.

An investment fund like a FUNCINE operates with investor logic: private capital, expectation of return, portfolio decisions. It's the model that capitalizes mature game industries around the world, and until now, our sector was outside this channel.


➔ Four concrete wins for Brazilian game studios

The express inclusion of electronic games is the headline, but IN 176 brings other relevant points that deserve attention for anyone running a studio.

First win: distribution can be financed up to 100%, with no mandatory counterpart. For games, this is the most strategic change of all. The oldest and most chronic gap in our funding has always been marketing and user acquisition. Brazilian grants fund production well, but rarely, almost never, fund the launch. Distribution entering as an eligible item with no counterpart opens a new door.

Second win: FUNCINES can now invest in equity of Brazilian audiovisual companies. Capitalization at the studio level, not just project by project. This changes the conversation with investors, opens the path to more robust rounds, and brings our model closer to what the global industry practices.

Third win: the maximum investment caps per project were eliminated. For ambitious productions, the regulatory structure no longer functions as a ceiling.

Fourth win: the definition of infrastructure was modernized. IN 176 includes technological innovation, advanced post-production, and new distribution technologies as eligible items. All directly relevant for electronic game development.


➔ How we got here: from the Marco Legal dos Games to IN 176

This isn't an isolated victory, and that's important to record. IN 176 is the direct operational consequence of the Marco Legal dos Games (Law 14.852/2024), which recognized electronic games as interactive audiovisual works. That legal recognition opened the path for games to be treated as part of the Brazilian audiovisual sector in instruments like FUNCINES.

Between May 2024 and May 2026, that path was built by an articulated effort of many hands. Abragames was present in every public consultation, with active participation from vice-president Luiza Guerreiro. Regional associations like our own ASCJogos, APGD (Associação Pernambucana dos Desenvolvedores de Games), APX (Associação Paulista de Desenvolvedores de Jogos), and several others joined the cause. The Ministry of Culture opened a specific working group for games within its Regulatory Agenda. The studio community showed up at public hearings, submitted comments within deadlines, fought the fight.

The result is what we're seeing now: the Brazilian games sector with a seat at the audiovisual table, with a solid legal basis, and with funding instruments being rewritten to include it.


➔ What's next

One operational note worth registering. The inclusion of games in IN 176 is definitive at the regulatory level, but ANCINE is not yet accepting game project submissions until it publishes a normative specific to the segment. That normative is formally on ANCINE's Regulatory Agenda 2026/2027 (Action 18), with a Ministry of Culture working group responsible for the final design. It's the next chapter, and we'll be tracking it closely.


In the meantime, what studios can do is prepare:

  • Understand how an investment fund works.

  • Structure accounting and governance compatible with private capital coming in.

  • Talk to FUNCINES managers and to law firms specialized in audiovisual.

  • Organize the documentation that was never asked for in a game grant but will be essential to access this new channel.

The takeaway: as of May 7, 2026, Brazilian games gained a capitalization channel that didn't exist before.

FUNCINES don't replace grants, they add to them. And they add precisely in the dimensions where our current instruments are most limited.


ASCJogos will continue tracking the topic and keeping our Santa Catarina ecosystem informed. If you run a studio in Santa Catarina and want to talk about what this could mean for your next 12 months, get in touch with us.


➔ Frequently asked questions

What is ANCINE's Instrução Normativa nº 176? It's the new regulation for FUNCINES, approved on May 7, 2026, that modernizes the rules for Brazil's audiovisual investment funds and, for the first time, expressly includes independent Brazilian electronic games as projects eligible for financing.

What are FUNCINES? They are private investment funds with tax incentives, regulated by ANCINE (Brazil's federal film agency), that channel private capital into Brazilian audiovisual projects. The investor receives a tax benefit for the contribution and gets a financial return if the financed project succeeds. They operate with investor logic, different from non-reimbursable grants.


Can game studios already raise capital via FUNCINES? Not yet. The inclusion of games is definitive in the text of IN 176, but ANCINE will only start accepting projects from the games segment after publishing a normative specific to games, which is being designed under Action 18 of the agency's Regulatory Agenda 2026/2027, together with a Ministry of Culture working group.


What changes in practice for game distribution and launch? IN 176 allows financing of up to 100% of distribution for independent works, with no mandatory counterpart. For games, this opens a path to finance launch and user acquisition, the most chronic gap in our current funding instruments.


Will FUNCINES replace the existing grant programs the games sector uses? No. FUNCINES and grants (FSA, Lei Rouanet, Lei do Audiovisual, FAPESC, FCC, Lei Paulo Gustavo, BNDES Garagem) serve different needs. Grants fund production with non-reimbursable resources or low counterpart. FUNCINES bring private capital with expected return. The ideal scenario is studios using both channels complementarily.


What's the connection between IN 176 and the Marco Legal dos Games? IN 176 is the direct operational consequence of Law 14.852/2024 (Brazil's Marco Legal dos Games, Games Legal Framework), which recognized electronic games as interactive audiovisual works. That legal recognition opened the path for games to be treated as part of the Brazilian audiovisual sector in instruments like FUNCINES.


➔ References

Legislation and official sources


Specialist analysis and journalism


Related ASCJogos content


➔ About the author

Leonardo Bilck is president of ASCJogos, co-founder and CTO of Plot Interactive (a game studio with 50+ projects), and co-founder and CTO of Truth and Tales (an award-winning social-emotional learning platform for children ages 4-8). He has more than a decade of experience in Brazil's game industry, focused on independent production, EdTech, and the institutional development of the sector.

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