It looks like one, sure.
You do most things with cards, and characters acquire more cards over time.
But even if you absolutely, utterly, and correctly loathe card-based systems, this game has none.

Units can’t be levelled, so losing them isn’t painful beyond the cost to replace them.
So how do you recruit more units?
How do you fight battles?

But it’s not a card game.
The former is fine.
They’re Not My Thing.

I’ve evenrecommendedafew, and only partly to use as a shield when calling you all terrible.
The latter, despite my whingeing, is also fine and valid.
It’s how we get new and weirder things.

There’s a third manifestation of The Card, though: a means to present information.
You didn’t gather cards, and they didn’tdoanything.
Whether to count these as “card games” is debatable.

Whether I don’t because I don’twantthem to be is an even less compelling debate.
With Songs of Silence though, I’m going further: the cards are a mere affectation.
They are merely a UI.

You could replace them with buttons orMMOaction bars and the design would be identical.
Cards must be stopped.
But I enjoy Songs of Silence.

It has a refreshing pace, thanks to doing away with HoMM’s building sites and constant resource hoovering.
Most intriguingly though, it replaces turn-based tactics with an auto battler.
The benefit is dropping the chore of telling everyone what to do.
There’s no building to dawdle over either.
Settlements grow automatically, ticking up at level thresholds if you spend material.
That increases production, and sometimes utility like healing or recruitment options.
Each has space for one special building, summoned by a hero with no prerequisites or research.
Armies are small, restricted to seven reserves, and recover very slowly even with healers.
Consequently, replenishing troops is everything.
The enemy have anti-infantry and area attackers.
I should switch the hearthguards for cavalry, and space them out.
Why do you leap across the room to obey their corporate orders the instant they Notify you?
Have some goddamn self respect).
But it could really use some clear indicators over towns and in battles.
Despite a gorgeous and rather slick introduction, the campaign is a dull story without a single memorable character.
Skirmishes offer the option of playing on two maps at once, linked by portals.
The other two are dull by comparison, with distinct rosters but nothing so dynamic.
Songs of Silence is almost fascinating.
But I certainly don’t hope it’s on the cards.