Crypto-assets: The AMF applies ESMA guidelines on the knowledge and competence of staff of crypto-asset service providers under MiCA
In the context of the implementation of the European MiCA (Markets in Crypto-Assets) regulation, the AMF complies with guidelines recently adopted by the European Securities and Markets Authority (ESMA). These guidelines set out the criteria for assessing the knowledge and competence of staff of crypto-asset service providers, as well as their training.
Adopted on 28 January 2026, the ESMA guidelines specify the criteria for assessing the knowledge and competence of staff of crypto-asset service providers (CASPs), in order to ensure that they fulfil their obligation to act in the best interests of their clients.
The guidelines first clarify the general framework applicable to CASPs with respect to their staff, in particular the requirement to ensure that staff are familiar with, understand and apply the internal policies and procedures designed to ensure compliance with MiCA.
Then, they distinguish between, on the one hand, criteria relating to the knowledge and competence of staff only providing information on crypto-assets to clients, and, on the other hand, criteria applicable to staff providing advice on crypto-assets to clients. In particular, the guidelines specify that CASPs must set a minimum number of training hours per year, which differs depending on whether staff provide only information on crypto-assets or advisory services on crypto-assets.
Finally, the guidelines set out organisational requirements relating to the assessment, maintenance and updating of the knowledge and competence of CASP staff. They also include an annex providing practical examples.
The AMF reminds that these guidelines will apply from 28 July 2026. They will apply to all authorised CASPs, whether authorised through licensing or through a notification procedure.
