On 13 April 2026, the Central Bank of Ireland issued a Notice of Intention proposing amendments to the Minimum Competency Code 2017. The CBI confirms that an Addendum to the MCC will apply to staff of Crypto-Asset Service Providers authorised under the Markets in Crypto-Assets Regulation. The Notice is a published proposal. The Addendum text will follow.
The controlling instruments are the Minimum Competency Code 2017 and the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) Minimum Competency Regulations 2017. Crypto-assets, defined by reference to Article 3(5) of Regulation (EU) 2023/1114 (MiCA), will be added as Category 9 to MCC Appendix 1. The Addendum implements the ESMA Guidelines on knowledge and competence under MiCA published in January 2026. The application date is 28 July 2026.
The direct addressees are Irish-authorised Crypto-Asset Service Providers and CASPs that passport into Ireland. Staff who provide information on crypto-assets or crypto-asset services must show at least six months of relevant full-time equivalent experience. Staff who provide advice must show at least one year. Firms must record competence assessments and supervise new-entrant staff during their accumulation periods.
The CBI will consider whether consequential amendments to the 2017 Regulations are needed. Existing MCC qualifications recognised for other retail financial product categories are not automatically valid for Category 9. Firms relying on grandfathering or qualifications acquired before MiCA application should re-check coverage before 28 July 2026.
We may advise on Irish CASP authorisation and supervisory readiness. We can call on a partner network of Irish counsel where local representation is required. Contact us to scope a piece of work. Work we undertake includes MCC gap assessment, training programme design, staff certification records, MiCA authorisation files and CBI engagement on conditions and grandfathering.
Source: Central Bank of Ireland, Notice of Intention on the Application of Crypto-Asset Knowledge and Competence Requirements, 13 April 2026, https://www.centralbank.ie/docs/default-source/regulation/how-we-regulate/authorisation/minimum-competency/notice-of-intention---application-of-crypto-asset-knowledge.pdf
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