ESMA Sets New Standards for Crypto Staff: MiCA's Knowledge Requirements

The European Securities and Markets Authority (ESMA) has launched a consultation to establish knowledge and competence criteria for crypto-asset service providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCA). The consultation, which began on February 17, 2025, aims to create uniform requirements for staff expertise across the European Union.

ESMA's proposal outlines different requirements for two categories of professionals: those providing general information about crypto-assets and those offering investment advice. For staff members who provide investment advice, ESMA proposes strict educational requirements, including a university degree in economics, law, or business administration, combined with one year of supervised experience. Alternatively, they can qualify through a secondary education degree plus three years of professional training and one year of supervised experience.

Information providers face less demanding requirements. They must complete a professional qualification program of at least 80 hours and gain six months of supervised experience. Staff members who have worked in the industry for more than a year before the guidelines take effect may continue their roles without additional certification.

The guidelines place heavy emphasis on understanding crypto-specific risks. Staff must demonstrate knowledge of market volatility, cybersecurity threats, and the mechanics of different blockchain protocols. They also need to understand market structures, valuation mechanisms, and the impact of major holders on market stability.

ESMA's proposal includes provisions for continuous professional development. Advisors must complete at least 20 hours of ongoing training each year, while information providers need 10 hours. These training programs must include assessments to verify that staff members retain the knowledge they gain.

Crypto-asset service providers (CASPs) face new organizational requirements under the guidelines. They must conduct yearly reviews of employee qualifications and maintain detailed documentation of compliance. The proposal also requires supervision of inexperienced staff for up to four years before they can work independently.

The consultation period remains open until April 22, 2025, allowing stakeholders to provide feedback on the proposed requirements. ESMA plans to review this input and publish the final guidelines in the third quarter of 2025. MiCA, which took effect on December 30, 2024, requires CASPs to ensure their employees have proper expertise. These new guidelines aim to create a framework for evaluating employee competence across EU markets.