ESMA MiCA Knowledge Competence Guidelines Application
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
- Review ESMA Guidelines ESMA35-24871704-2922 on knowledge and competence criteria for CASP personnel
- Assess current staff competency against the new MiCA-specific knowledge requirements
- 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)
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