Central Bank of Ireland Amends MCC to Cover Crypto-Asset Staff, Ireland, April 2026

On April 13, 2026, the Central Bank of Ireland (CBI) issued a Notice of Intention outlining planned amendments to the Minimum Competency Code 2017 (MCC) to incorporate knowledge and competence requirements for staff at Crypto-Asset Service Providers (CASPs). The amendments implement the ESMA MiCA Guidelines on knowledge and competence published in January 2026. The MCC amendments are proposed and will take effect on 28 July 2026, the same date as the ESMA MiCA Guidelines' application date.

The controlling authority is the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114, "MiCA"), applicable to CASPs since 30 December 2024. Article 81(7) of MiCA requires CASPs providing advice on crypto-assets to ensure that natural persons providing advice or information on their behalf possess the necessary knowledge and competence. The CBI's MCC amendments domesticate this obligation into the Irish supervisory framework as a new Category 9 in Appendix 1 of the MCC, covering crypto-assets as defined in Article 3(5) of MiCA. Two staff categories are in scope: those giving information on crypto-assets or crypto-asset services, and those providing advice on crypto-assets or crypto-asset services.

CASPs authorized in Ireland must comply with the amended MCC from 28 July 2026. Staff giving information must complete 10 hours of CPD per year; advice-giving staff must complete 20 hours. Minimum experience thresholds apply: six months for information-giving staff and one year for advice-giving staff. No grandfathering relief is available for crypto-asset functions. Only an experience-based transitional arrangement applies for staff already active in those roles on 28 July 2026 — they must demonstrate one year of relevant experience prior to that date.

Following publication of the MCC Addendum, the CBI may also consider consequential amendments to the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) Minimum Competency Regulations 2017. CASPs applying for authorization through the CBI's portal — which opened for submissions on 2 April 2026 — must factor these competency requirements into staffing plans. The absence of a grandfathering pathway means in-scope staff must demonstrate qualifying experience by 28 July 2026 or operate under supervision for up to four years while acquiring required qualifications.

Our firm advises on MiCA compliance, CASP authorization, and crypto-asset regulatory matters in Ireland and across the EU. We maintain a dedicated partner network for Irish regulatory proceedings and welcome inquiries from CASPs, exchanges, and financial institutions building out Irish operations. Our work in this area covers MiCA authorization support, competency framework design, CASP staff training compliance, crypto-asset regulatory advice, Irish financial services regulatory guidance, and MiCA knowledge and competence structuring.

Source: Central Bank of Ireland, Notice of Intention - Minimum Competency Code 2017 Amendment for Crypto-Asset Service Providers, 13 April 2026. Official source: https://www.centralbank.ie/regulation/markets-in-crypto-assets-regulation — confirmed April 16, 2026. Controlling regulation: Regulation (EU) 2023/1114 (MiCA), Article 81(7); Minimum Competency Code 2017, Appendix 1 (proposed new Category 9).

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