Dr. Fidelio Tata.

PROVIDER OF
PROFESSIONAL QUALI­FI­CA­TION AND
CONTINUOUS PRO­FESSIO­NAL DE­VELOP­MENT (CPD) FOR
CRYPTO-ASSET SER­VICE PRO­VIDERS (CASPs).

BACKGROUND.

On 11 July 2025, the European Securities and Markets Authority (ESMA) published guidelines for the assessment criteria for knowledge and competence under the Markets in Crypto Assets Regulation (MiCA). These guidelines suggest minimum qualification, experience and continuous professional development (CPD) thresholds for staff providing information or advice on crypto-asset and crypto-asset services to clients.

WHAT LEVEL OF PRO­FESSIO­NAL QUALI­FI­CATION IS EX­PEC­TED OF CASP STAFF?

ESMA pro­poses, among other routes for staff to gain the appro­pri­ate know­led­ge, a mini­mum of 80 hours of pro­fessio­nal quali­fi­cation which CASP’s staff giving in­for­ma­tion about cryp­to-as­sets or cryp­to-as­set ser­vices and a minimum of 160 hours of pro­fession­al quali­fi­cation which CASP’s staff giving ad­vice about cryp­to-assets or cryp­to-asset ser­vi­ces should ob­tain prior to pro­vi­ding such in­for­ma­tion. This should be de­monstra­ted by pas­sing an assess­ment con­duc­ted either by the cryp­to-asset ser­vice pro­vider it­self or by an ex­ter­nal body.

WHAT LEVEL OF CON­TINU­OUS PRO­FESSIO­NAL DE­VELOP­MENT (CPD) IS EX­PEC­TED OF CASP STAFF IN ORDER TO MAIN­TAIN AND UP­DATE THEIR KNOW­LED­GE AND COM­PE­TENCE ON AN ON­GOING BASIS?

ESMA pro­poses that CASPs de­ter­mine the ade­quate mi­ni­mum num­ber of CPD hours per year that staff pro­vi­ding in­for­ma­tion on cryp­to-assets or cryp­to-asset ser­vices should com­plete, based on the na­ture of these assets and ser­vices. Even staff pro­vi­ding in­for­ma­tion or ad­vice on a limit­ed range of the least com­plex cryp­to-assets or cryp­to-asset ser­vices should com­plete 10 or 20 hours of CPD, re­spec­tive­ly. CPD should in­clude an assess­ment of par­ti­ci­pants' know­ledge and com­pe­tence.

WHY SHOULD THE CPD BE TAILORED TO THE TRAIN­ING NEEDS OF CASPs?

ESMA con­firms that staff pro­vi­ding in­for­ma­tion must de­monstra­te the ne­cessary know­ledge and com­pe­tence only for the cryp­to-assets and cryp­to-asset ser­vices offered by the CASP, but not for cryp­to-assets that are tech­ni­cal­ly with­in the scope of the cryp­to-asset ser­vice but are not actual­ly offered by the CASP in any of its ser­vices. There­fore, CPD must be adapt­ed to each CASP’s spe­ci­fic busi­ness model. The exist­ing know­led­ge and com­pe­tence of staff mem­bers pro­vi­ding in­for­ma­tion on cryp­to-assets or cryp­to-asset ser­vices should also be taken into con­si­de­ration, as well as appli­ca­ble re­gu­la­tory chang­es, key mar­ket de­velop­ments and newly emerg­ing tech­no­lo­gies.

WHY SHOULD CASPs START PLAN­NING THEIR CPD PRO­GRAMS NOW AL­READY?

ESMA has de­cided to set the appli­ca­tion date for their guide­lines six months after the publi­cation of their trans­la­tion. How­ever, im­ple­ment­ing a firm-wide CPD pro­gram re­quires some six months’ lead time for pre­pa­ra­tion. This in­cludes identi­fy­ing staff who needs train­ing, sche­du­ling train­ing ses­sions (both on-site and webi­nar-based) and pre­pa­ring train­ing ma­terial.

HOW IS THE CRYPTO LITERACY OF CASP STAFF REVIEWED?

ESMA re­quires CASPs to carry out an in­ter­nal or ex­ter­nal re­view at least once a year of their staff mem­bers’ de­velop­ment and ex­perience needs. They must also assess re­gu­la­tory de­velop­ments and take the neces­sary action to com­ply with appli­cable re­quire­ments. The re­view should also en­sure that staff have the appro­pri­ate quali­fi­cations and main­tain and up­date their know­ledge and com­pe­tence through con­tinuous pro­fessional de­velop­ment or training, in line with the re­le­vant mi­ni­mum guidance set out in ESMA guide­lines. It should also in­clude spe­cific train­ing be­fore any new type of cryp­to-asset or cryp­to-asset ser­vice is offered by the cryp­to-asset ser­vice pro­vider.

MY OFFER.

Drawing on over 30 years of pro­fessional teaching ex­perience and my previous CPD pro­grams de­livered at a CASP in Ger­many in 2024/25, I can assist with the plan­ning, de­sign and exe­cu­tion of be­spoke pro­fessional quali­fi­cations and con­tinuous pro­fessional de­velop­ment train­ing pro­grams. This in­cludes:

• The assess­ment of which staff members fall with­in the train­ing scope set out by ESMA;
• The assess­ment of staff’s current level of quali­fi­cation and know­ledge of, for example, re­gu­la­tory changes, new cryp­to-assets and ser­vices avail­able on the market through exams;
• De­sign­ing train­ing in the form of re­cord­ed train­ing courses, on­line se­mi­nars, on-site train­ing and work­shops in­vol­ving re­le­vant de­part­ment re­pre­senta­tives;
• Designing of CASP-spe­cific and up­dated train­ing material;
• The execu­tion of train­ing (as speaker and/or modera­tor);
• Exami­na­tion and docu­mentation of train­ing out­comes.