Fidelio Tata, PhD⎢Embedded MiCA CASP CPD & Competence Frameworks
Embedded CPD and Competence Infrastructure for MiCA-Authorised CASPs:
Role-based training, management CPD and audit-ready evidence under ESMA expectations
My CASP CPD and advisory programmes help MiCA-authorised crypto-asset service providers build, maintain and evidence internal knowledge and competence capabilities. Programmes are available as documented annual CPD cycles, supported by audit-ready regulatory documentation.
Sample programme structures
- 10-Hour MiCA CASP CPD Programme:
Annual continuing professional development for staff providing information on crypto-assets and crypto-asset services. View sample 10-hour CPD programme. - 20-Hour MiCA CASP CPD Programme:
Annual continuing professional development for staff providing information and/or advice on crypto-assets and crypto-asset services. View sample 20-hour CPD programme. - 40-Hour MiCA CASP Initial Qualification Programme:
Structured initial qualification programme for staff providing information on crypto-assets and crypto-asset services. View sample 40-hour initial qualification programme. - 3-Hour MiCA Management Programme:
Management CPD and oversight briefing for senior managers, board members and management body members responsible for the oversight of crypto-asset services. View sample 3-hour management programme.
For CASPs seeking to document a broader competence and governance approach beyond individual training programmes, an Embedded CASP CPD and Competence Framework can be implemented. The framework integrates role-based learning paths, management CPD, competence assessments, governance documentation and audit-ready evidence into a coherent internal competence model. View sample Embedded CASP CPD and Competence Framework proposal.
Rather than offering stand-alone training only, the programmes are designed as embedded competence frameworks: role-based learning paths, management CPD, CASP-specific workshops, documented assessments and audit-ready evidence aligned with ESMA’s Knowledge & Competence Guidelines and broader supervisory expectations on governance, substance and effective oversight.
The programmes support CASPs in demonstrating that relevant staff, senior managers and control functions maintain the regulatory knowledge, practical skills and crypto-asset expertise required to perform their roles effectively. Each engagement can include a documented Regulatory Compliance Pack with mapped CPD hours, participation records, assessment results, role-based competency outcomes and recommended next steps for internal governance and supervisory review.
The offering is designed for MiCA-authorised CASPs and is particularly relevant for client-facing staff, compliance, risk, legal, AML, IT, audit and outsourcing management functions, as well as senior managers and management body members responsible for effective oversight of CASP activities. A dedicated management CPD module can be used to evidence board-level and senior executive understanding of crypto-asset services, operational risks, outsourcing, governance and supervisory expectations.
WHY AN EMBEDDED CPD MODEL MATTERS
Training can be outsourced.
Competence and effective oversight remain internal responsibilities.
ESMA’s approach to CASP authorisation and ongoing supervision increasingly emphasises substance, governance, effective oversight and sufficient internal skills and experience. External training can support these objectives, but internal competence capabilities and effective oversight remain essential responsibilities of the CASP. The embedded CPD model therefore combines external expertise with internal participation by management, compliance, risk, IT, AML and other key functions.
BACKGROUND: ESMA KNOWLEDGE & COMPETENCE GUIDELINES
On 11 July 2025, the European Securities and Markets Authority (ESMA) published Guidelines for the criteria on the assessment of knowledge and competence under the Markets in Crypto‑Assets Regulation (MiCA). These Guidelines set out minimum expectations for qualifications, professional experience and continuous professional development (CPD) for staff providing information or advice on crypto‑assets and crypto‑asset services to clients. The official translations into all EU languages were published on ESMA’s website on 28 January 2026, starting a two‑month period during which competent authorities had to notify ESMA whether they comply or intend to comply with the Guidelines. The Federal Financial Supervisory Authority (Bafin) listed the ESMA guidelines as applicable from 27 July 2026 and will therefore reflect them in its supervisory practice.
MINIMUM PROFESSIONAL QUALIFICATION FOR CASP STAFF
ESMA sets out several possible qualification pathways. For staff providing information on crypto-assets or crypto-asset services, one example is a professional qualification of at least 80 hours combined with at least six months of relevant supervised experience. Alternatively, at least one year of relevant supervised experience may be sufficient. For staff providing advice, ESMA identifies, among other pathways, a professional qualification of at least 160 hours combined with at least one year of relevant supervised experience. Other qualification and experience pathways are also available. The relevant knowledge and competence must be demonstrated by passing an assessment.
CPD REQUIREMENTS TO MAINTAIN KNOWLEDGE AND COMPETENCE
ESMA expects that CASPs determine the adequate minimum number of CPD hours per year that staff providing information or advice on crypto‑assets or crypto‑asset services should complete, taking into account the nature and complexity of the assets and services concerned as well as staff’s existing knowledge and experience. Even staff providing information or advice on a limited range of the least complex crypto‑assets or crypto‑asset services should complete at least 10 or 20 hours of CPD per year, respectively, with CPD including verification of the participants’ knowledge and competence rather than mere attendance.
WHY CPD MUST BE TAILORED TO EACH CASP
ESMA confirms that staff providing information must demonstrate the necessary knowledge and competence only for the crypto‑assets and crypto‑asset services actually offered by the CASP, not for all crypto‑assets that are technically within the scope of the service. CPD must therefore be adapted to each CASP’s specific business model. When designing CPD, CASPs should take into account existing staff knowledge and competence, regulatory changes, key market developments and newly emerging technologies.
WHY CASPs SHOULD PLAN THEIR CPD PROGRAMMES EARLY
The Guidelines will apply from 27 July 2026. Implementing a firm‑wide CPD programme typically requires three to six months of lead time, including identifying staff in scope, scheduling on‑site and webinar‑based sessions, and preparing or customising training materials. CASPs that start planning early can phase in training, testing and documentation rather than compressing everything into the months immediately before the application date.
HOW CASPs SHOULD REVIEW STAFF CRYPTO-ASSET COMPETENCE
ESMA requires CASPs to carry out at least annual internal or external reviews of their staff members’ development and experience needs, to assess regulatory developments and to take the necessary action to comply with applicable requirements. These reviews should ensure that staff hold appropriate qualifications and maintain and update their knowledge and competence through continuous professional development or training, in line with the minimum guidance set out in the Guidelines, and should include specific training before any new type of crypto‑asset or crypto‑asset service is offered.
MY OFFER: EMBEDDED MiCA CASP CPD AND COMPETENCE FRAMEWORKS
Based on my more than 30 years of professional experience in financial markets, academia and advisory projects, as well as tailored training programmes already delivered for CASPs, I support crypto-asset service providers in the implementation and documentation of MiCA-aligned CPD and competence frameworks, including:
- Conducting skills gap assessments to identify training needs aligned with staff roles and MiCA competence requirements
- Designing customized training programmes calibrated to CASP business models and the nature of crypto assets and services
- Delivering role‑based training modules that build regulatory knowledge, practical skills, and supervisory awareness
- Facilitating interactive learning experiences through workshops, case studies, and competency assessments
- Providing documented evidence of CPD engagement, including certificates, assessments, and participation records
- Maintaining a regulatory audit trail and CPD documentation via a comprehensive Regulatory Compliance Pack that supports supervisory review and internal compliance reporting, including:
- Mapped CPD hours linked to ESMA MiCA knowledge & competence expectations
- Audit-ready evidence in PDF/Excel
- Role-based competency outcomes
- Supervisory submission support materials
- Preparing post‑training competency reports summarizing outcomes, compliance mapping, and recommended next steps
- Bi‑weekly CASP Knowledge & Competence Monitor (by invitation only, typically bundled with CASP CPD training and advisory mandates)
Continuing Professional Development (CPD) is essential for Crypto-Asset Service Providers (CASPs) under MiCA, ensuring staff maintain up-to-date knowledge of crypto-assets, services, and regulatory requirements. My embedded CASP competence programmes help firms establish, maintain and evidence internal knowledge and competence capabilities under MiCA, combining role-based learning, management involvement and audit-ready documentation.
The training is designed to reflect both ESMA and relevant national competent authority expectations on staff competence and ongoing education. Participants build the capabilities needed for MiCA‑compliant initial qualification and annual CPD, supported by audit‑ready documentation and clearly evidenced learning outcomes.
Client reference: V-Bank AG
