ESMA’s MiCA Guidelines on Knowledge and Competence: Preparing for a New Standard

Χρηματοοικ.-Ασφαλιστικά-Τραπεζικά,⠀

The European crypto-asset sector is entering a decisive phase. With the Markets in Crypto-Assets Regulation (MiCA) coming into effect, firms across the Union will face new expectations that go beyond licensing or operational compliance. One of the most significant, and perhaps least anticipated, requirements lies in the area of knowledge and competence. ESMA’s recently published Guidelines, which take effect six months after their official translations are released, will make competence frameworks a central part of regulatory oversight for crypto-asset service providers (CASPs).

What makes these guidelines so important is that they do not treat competence as a one-off milestone. Instead, they place it on the same footing as capital adequacy or operational resilience: an ongoing obligation that must be evidenced year after year. Staff members interacting with clients will need to demonstrate that they possess the skills and knowledge appropriate to their role. Those who provide general information will be assessed differently from those who advise on suitability or valuation. ESMA also stresses that competence cannot be fulfilled by a single exam or workshop; it must be supported through continuing professional development. Typically, this means ten to twenty hours of structured learning per year, with firms keeping audit-ready records that supervisors may request at any time.

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For many CASPs, this represents a cultural shift. The crypto industry has often prided itself on agility and informality, yet MiCA pushes it towards the kinds of governance structures more familiar to banks or investment firms. Building role-based competence frameworks will not only require new training plans, but also careful coordination between compliance and human resources functions. For example, a compliance officer may need to work hand-in-hand with HR to map out which roles fall under the information-giving category, which fall under the advisory category, and what kind of evidence will satisfy a regulator across different Member States.

There are practical challenges here. Smaller CASPs may find it difficult to dedicate resources to designing frameworks and tracking professional development. Larger firms, meanwhile, will face the complexity of aligning diverse teams across jurisdictions. But the risk of neglecting this obligation is clear: supervisory authorities are unlikely to be lenient if firms fail to show that their staff are both competent and current in their knowledge. In a sector where investor trust remains fragile, reputational damage from non-compliance could be as damaging as formal penalties.

Seen from a broader perspective, these requirements also mark a turning point in how professionalism is defined in the crypto industry. By introducing mandatory continuing professional development, MiCA effectively places crypto-assets within the same tradition as financial advisory and investment services. It signals to the market that credibility will depend not only on technology and innovation, but also on the depth of human expertise behind it. A firm that can demonstrate its people are trained, monitored, and accountable is far more likely to inspire confidence among both clients and regulators.

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Looking ahead, the message is clear. Knowledge and competence are no longer optional or secondary considerations. They form part of the regulatory backbone of MiCA, and their enforcement will shape how CASPs operate in practice. Those who act early — by embedding learning into their business culture and ensuring audit-ready frameworks — will not only meet regulatory expectations but also distinguish themselves in an industry still striving for maturity and trust.

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