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Routine Guidance Added Final

ESMA MiCA Knowledge Competence Guidelines Application

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Published April 1st, 2026
Detected April 1st, 2026
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Summary

The CSSF issued Circular 26/909 directing Crypto-Asset Service Providers (CASPs) to comply with ESMA Guidelines on knowledge and competence criteria under MiCA. The circular applies ESMA's competency requirements (ESMA35-24871704-2922) to Luxembourg-licensed CASPs. Regulated entities must ensure staff involved in crypto-asset services meet the specified knowledge and competence standards.

What changed

The CSSF has adopted ESMA's Guidelines on the assessment of knowledge and competence under the Markets in Crypto-Assets Regulation, requiring Luxembourg-licensed Crypto-Asset Service Providers to implement competency standards for personnel providing crypto-asset services. The guidelines establish criteria for assessing whether CASP staff possess adequate knowledge of crypto-assets, MiCA requirements, and related risks.\n\nCASPs should review their current staff training and competency frameworks against the ESMA guidelines and make necessary updates to ensure compliance. While no specific compliance deadline is stated, CASPs should treat this as applicable immediately and integrate these competency requirements into their operational compliance programs. The CSSF expects adherence to these guidelines as part of MiCA implementation.

What to do next

  1. Review ESMA Guidelines ESMA35-24871704-2922 on knowledge and competence criteria for CASP personnel
  2. Assess current staff competency against the new MiCA-specific knowledge requirements
  3. Update training and certification programs to address any gaps in crypto-asset competency standards

Source document (simplified)

Published on 1 April 2026 CSSF circular

Circular CSSF 26/909

Application of the Guidelines of the European Securities and Markets Authority for the criteria on the assessment of knowledge and competence under the Markets in Crypto Assets Regulation (MiCA) (ESMA35-24871704-2922)

Main topic:

Relevant for

Named provisions

Markets in Crypto-Assets (MiCA/MiCAR) Crypto-Assets Service Providers (CASPs)

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
CSSF
Published
April 1st, 2026
Instrument
Guidance
Legal weight
Non-binding
Stage
Final
Change scope
Minor
Document ID
Circular CSSF 26/909

Who this affects

Applies to
Investors Technology companies Financial advisers
Industry sector
5239.1 Cryptocurrency & Digital Assets 5112 Software & Technology 5231 Securities & Investments
Activity scope
Crypto-Asset Services Investment Advisory Services Financial Services Licensing
Geographic scope
LU LU

Taxonomy

Primary area
Financial Services
Operational domain
Compliance
Compliance frameworks
Dodd-Frank MiCA
Topics
Securities Consumer Protection

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