The Central Bank of Ireland has issued a Notice of Intention outlining planned changes to the Minimum Competency Code 2017 (MCC) to incorporate knowledge and competence requirements for staff in Crypto-Asset Service Providers (CASPs), in order to align with the ESMA MiCA Guidelines. These changes will come into effect on 28 July 2026.

CASPs have been regulated under the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) (MiCA) since 30 December 2024 and must be authorised to operate within the EU. In January 2026, ESMA published its MiCA Guidelines setting out knowledge and competence standards for staff who provide information on, or advice relating to, crypto-assets. National regulators are expected to incorporate the guidelines into their supervisory frameworks. Accordingly, the proposed MCC amendments are a domestic Irish overlay on top of what is already an EU-level obligation.

Who is affected?

Under Article 81(7) of MiCA, CASPs providing advice on crypto-assets must ensure that natural persons providing advice or information about crypto-assets or a crypto-asset service on their behalf possess the necessary knowledge and competence to fulfil their obligations.

The competency requirements apply to two categories of staff:

• Staff who give information on crypto-assets or crypto-asset services
• Staff who provide advice on crypto-assets or crypto-asset services

Competency Standards

A person performing MiCA Services will not be taken to comply with the Minimum Competency Standards unless they have demonstrated appropriate experience to perform the relevant function. Where a person has not yet acquired the appropriate qualification or experience (or both), they may only perform the relevant function under the supervision of an appropriately qualified and experienced person, for a maximum period of four years.

“Appropriate experience” is specifically defined by reference to the role performed:

• for staff giving information on crypto-assets or crypto-asset services, appropriate experience means successfully demonstrating the ability to perform the relevant services through previous work on a full-time equivalent basis for a minimum period of six months.
• for staff providing advice on crypto-assets or crypto-asset services, the minimum period is one year.

Continuing Professional Development (CPD)

A person who is giving information on crypto-assets or crypto-asset services must complete 10 hours of CPD per year, and a person who is providing advice on crypto-assets or crypto-asset services must complete 20 hours of CPD per year.

Importantly, the CPD material for persons providing MiCA Services must be relevant to crypto-assets or the provision of crypto-asset services.

Grandfathering – not available for crypto-asset functions

A critical point; there is no grandfathering relief available for staff providing crypto-asset information or advice.

While a transitional arrangement exists for staff who are already active in crypto-asset roles as at 28 July 2026, it is experience based rather than qualification based as set out below:

• existing members of staff giving information on crypto-assets or crypto-asset services on 28 July 2026 may be considered as having the necessary knowledge and competence if they have successfully given such information on a full-time equivalent basis, under or without supervision, for a minimum period of one year prior to the entry into application of the ESMA MiCA Guidelines.
• existing members of staff providing advice on crypto-assets or crypto-asset services on 28 July 2026 may be considered as having the necessary knowledge and competence if they have successfully provided such advice on a full-time equivalent basis, under or without supervision, for a minimum period of one year prior to the entry into application of the ESMA MiCA Guidelines.

Crypto-assets added to the list of retail financial products

In formalising crypto-assets within the MCC framework, crypto-assets, as defined in Article 3(5) of MiCA, will be added as a new Category 9 to Appendix 1 of the MCC’s list of retail financial products.

Comment

These latest changes represent the next phase of Ireland’s domestic implementation of MiCA, bringing CASP staff squarely within the same competency and professional development framework that already applies to staff providing investment and other regulated financial services.

As a next step the CBI will publish the Addendum to the MCC and also consider whether any consequential amendments may need to be made to the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) Minimum Competency Regulations 2017.

In line with the application of the ESMA MiCA Guidelines, the MCC amendments will apply on and from 28 July 2026.

Our Financial Regulation Group regularly advises CASPs and other clients on all aspects of MiCA compliance and the Irish domestic regulatory framework. If you require further information, please contact a member of the Financial Regulation Group or your usual Arthur Cox contact.

The content of this briefing is provided for information purposes only and is not legal or other advice.