TLDR

• ESMA launched a consultation to establish knowledge and competence criteria for crypto-asset service providers (CASPs) under MiCA regulation, with the consultation period running until April 22, 2025
• Staff providing crypto advice must meet higher standards, including university degree or equivalent, 160 hours of training, and one year of experience, while information providers need 80 hours of training and six months of experience
• Annual continuing education is required – 20 hours for advisors and 10 hours for information providers
• CASPs must conduct yearly internal reviews of employee qualifications and maintain documentation of compliance
• Final guidelines expected in Q3 2025, with full MiCA implementation planned for 2025

The European Securities and Markets Authority (ESMA) launched a consultation on February 17, 2025, to establish clear standards for professionals working in the crypto-asset service industry. The new guidelines aim to create uniform requirements for staff expertise across the European Union under the Markets in Crypto-Assets Regulation (MiCA).

The consultation outlines different requirements for two categories of professionals: those providing general information about crypto-assets and those offering investment advice. These standards cover educational qualifications, work experience, and ongoing training requirements.

For staff members who provide investment advice on crypto-assets, ESMA proposes strict educational requirements. These professionals must hold 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 Proposal

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 builds on existing financial market standards under the Markets in Financial Instruments Directive (MiFID II). However, ESMA has adapted these requirements to address unique aspects of crypto-asset markets, such as decentralized technologies and specific market risks.

For advisors transitioning from traditional finance, ESMA provides alternative qualification paths. Professionals with two years of experience under MiFID II or IDD regulations can qualify after completing six months of supervised crypto-asset experience.

The guidelines outline specific knowledge requirements for staff providing information about crypto-assets. These include understanding tax implications, transaction costs, and differences between investor protections under MiCA and traditional financial services regulations.

ESMA’s proposal requires CASPs to develop tailored training programs based on employee roles and responsibilities. These programs must cover market abuse prevention and anti-money laundering regulations, along with core crypto-asset knowledge.

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.

The timing of these guidelines aligns with the broader implementation of MiCA, which aims to establish a harmonized legal framework for digital assets throughout the European Union. Full implementation of MiCA is expected in 2025.

Market participants, including CASPs, investors, financial institutions, and industry associations, can submit comments on the proposed standards during the consultation period.