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On 7 July 2026, ESMA published its latest compliance table on the MiCA Guidelines for the assessment of knowledge and competence.
Firms should ensure that competence frameworks are properly documented and capable of being evidenced to regulators as part of ongoing supervisory reviews
The update provides an overview of how EU national competent authorities are approaching the implementation of ESMA’s guidelines, including the position of the Cyprus Securities and Exchange Commission (CySEC). It also reflects the increasing supervisory focus on ongoing operational compliance standards under the Markets in Crypto-Assets Regulation (MiCA).
Official source: ESMA, Compliance table – Guidelines on the criteria for the assessment of knowledge and competence under MiCA (published on ESMA’s website on 7 July 2026).
Cyprus regulatory position
According to ESMA’s compliance table published on 7 July 2026, CySEC has indicated that it intends to comply with the MiCA knowledge and competence guidelines once the necessary regulatory proceedings have been completed.
The Central Bank of Cyprus has also indicated an intention to comply where a relevant institution falls within its supervisory remit.
This position indicates that Cyprus is progressing towards alignment with ESMA’s supervisory expectations on staff competence, training and ongoing professional standards for crypto-asset service providers.
Official source: ESMA, Compliance table – Guidelines on the criteria for the assessment of knowledge and competence under MiCA (7 July 2026):
Why this matters
As MiCA supervision moves beyond the initial authorisation phase, regulators are placing increasing emphasis on whether crypto-asset service providers (CASPs) have effective internal frameworks to ensure that client-facing services are provided by appropriately knowledgeable and competent personnel.
ESMA’s guidelines establish minimum knowledge and competence standards for staff providing information or advice on crypto-assets or crypto-asset services. Their objective is to strengthen investor protection and promote consistent supervisory expectations across the European Union.
The guidelines form part of ESMA’s broader supervisory convergence work under MiCA and are intended to support consistent application of regulatory requirements by national competent authorities and market participants.
Official source: ESMA, Guidelines on the criteria for the assessment of knowledge and competence under MiCA: Guidelines.
Who should pay attention?
This update is particularly relevant for:
- Cyprus-authorised CASPs under MiCA,
- Financial entities providing crypto-asset services under Article 60 of MiCA*,
- Firms preparing for MiCA authorisation or passporting activities in the EU,
- Compliance, risk and HR teams responsible for staff competence frameworks,
- Businesses providing crypto-asset information, recommendations or advisory services to clients.
The relevant requirements arise under Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), including Article 60 concerning certain financial entities providing crypto-asset services.
What should firms do now?
Firms should review whether their existing governance and compliance frameworks adequately address MiCA knowledge and competence expectations, including:
- identifying staff involved in providing crypto-asset information or advice
- implementing documented training programmes and competence assessments
- maintaining evidence of qualifications, experience and continuing professional development (CPD)
- ensuring staff understand crypto-asset risks, costs, market functioning, AML/TF considerations, DLT-related risks and investor protection requirements
- reviewing controls around automated or semi-automated client information and advisory tools.
Firms should also ensure that competence frameworks are properly documented and capable of being evidenced to regulators as part of ongoing supervisory reviews.
AGPLAW FS Regulatory Team takeaway
ESMA’s publication on 7 July 2026 is a timely reminder that MiCA compliance does not end with authorisation. CASPs and other regulated firms should ensure that their people, processes and governance arrangements are prepared for the next phase of regulatory scrutiny.
The ESMA compliance table confirms that Cyprus is moving towards implementation of the MiCA knowledge and competence framework, reinforcing the importance of proactively aligning internal procedures with EU supervisory expectations.
Our FS Regulatory Team can assist firms in reviewing MiCA readiness, including staff competence frameworks, compliance policies, training programmes and supervisory documentation.
*Article 60 allows certain existing regulated financial entities, such as banks, investment firms, e-money institutions, UCITS managers and AIFMs, to provide specific crypto-asset services without applying for a full standalone CASP licence, provided they notify their competent authority and only provide services equivalent to their existing authorisation.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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