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ESMA Guidelines on Crypto Company Staff Competence Requirements Under MiCA

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Summary

Finantsinspektsioon has adopted ESMA's Guidelines for the criteria on the assessment of knowledge and competence under the Markets in Crypto-Assets Regulation (MiCA) as advisory guidelines. Providers of crypto asset services must ensure staff handling clients have appropriate qualifications and experience. Staff giving advice face higher knowledge requirements than those issuing information. Annual competency assessments and regular additional training are mandatory. The guidelines enter into force on 28 July 2026.

“Providers of crypto asset services must also assess at least once a year whether the knowledge and skills of their staff meet the requirements and must organise regular additional training for their staff.”

Why this matters

Crypto asset service providers should audit their current staff competence frameworks before the July 2026 effective date. The distinction between information-only and advisory roles means firms need to map which employees fall into each category and ensure advisory staff meet the higher knowledge threshold.

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What changed

Finantsinspektsioon has issued ESMA's Guidelines for the criteria on the assessment of knowledge and competence under the Markets in Crypto-Assets Regulation (MiCA) as advisory guidelines. The guidelines distinguish between staff who give clients advice (requiring more knowledge and skills) and those who only issue information. Providers of crypto asset services must assess staff competence annually and provide regular additional training.

Crypto asset service providers operating in Estonia must prepare to comply with these new competence requirements by 28 July 2026. Firms should inventory their staff training programmes and assessment processes to ensure they meet the MiCA standards. The harmonised EU-wide guidelines are intended to increase trust in the crypto asset market and provide better investor protection.

What to do next

  1. Assess at least once a year whether the knowledge and skills of staff meet the requirements
  2. Organise regular additional training for staff

Archived snapshot

Apr 21, 2026

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Finantsinspektsioon is clarifying the competence requirements for staff of crypto companies

26/03/2026

Finantsinspektsioon issued the European Securities and Markets Authority guidelines “Guidelines for the criteria on the assessment of knowledge and competence under the Markets in Crypto Assets Regulation (MiCA)” as advisory guidelines. Providers of crypto asset services need to make sure that staff handling clients have the qualifications and experience needed to provide services.

The guidelines clarify the knowledge and skills expected of providers of crypt asset services depending on whether they give clients information or advice. Staff giving advice are required to have more knowledge and skills than those who only issue information on crypto asset services. Providers of crypto asset services must also assess at least once a year whether the knowledge and skills of their staff meet the requirements and must organise regular additional training for their staff.

The guidelines are intended to harmonise with the principles of the European Union for assessing the knowledge and skills of staff who inform clients about crypto assets and crypto asset services or give advice to clients on those matters. Finantsinspektsioon believes that these guidelines will help increase trust in the crypto asset market and will give investors better protection.

The guidelines will come into force from 28 July 2026.

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Last updated

Classification

Agency
FI Estonia
Published
July 28th, 2026
Compliance deadline
July 28th, 2026 (98 days)
Instrument
Guidance
Branch
Executive
Joint with
ESMA
Legal weight
Non-binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Financial advisers Technology companies
Industry sector
5239.1 Cryptocurrency & Digital Assets
Activity scope
Staff training compliance Licensing requirements Investor protection
Geographic scope
EE EE

Taxonomy

Primary area
Securities
Operational domain
Compliance
Topics
Financial Services Consumer Protection

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