MiCA explainer

MiCA CASP Staff Competence 28.07.2026

Explanation and Watchlist: What Changes on 28 July, to Whom ESMA's Knowledge and Competence Guidelines Apply, and What Baltic and Nordic CASPs Must Achieve by the Deadline.

Toms Ābeltiņš

17 July 20266 min read

There have been no significant new regulatory developments in our segment over the past 24 hours. This explanatory article covers the next MiCA deadline: 28 July, when ESMA's guidelines on the knowledge and competence of CASP staff (ESMA35-1872330276-2380) come into force, affecting all licensed Baltic and Nordic exchanges.

Over the past 24 hours, there have been no new, definitively datable regulatory developments in the Baltic (LV, LT, EE) and Nordic (FI, SE, NO, DK) crypto exchange, hardware wallet, card, and tax tool segment. The most recent significant event - Ledger Donjon's published 'laser' vulnerability in Tangem cards and Tangem's response (9-10 July) - has already been covered in a separate article on 13 July, so we are not repeating it as fresh news. Today's release is therefore an explanatory and watchlist article on the next specific MiCA deadline, which directly affects all licensed exchanges in our region: ESMA's guidelines on the knowledge and competence of Crypto-Asset Service Provider (CASP) staff come into force on 28 July.

What Happens on 28 July

This refers to ESMA guidelines with reference number ESMA35-1872330276-2380 - "Guidelines on the criteria for the assessment of knowledge and competence under MiCA". ESMA published its final report on 11 July 2025, but the guidelines come into force six months after the official translations are published in all EU languages. The translations were published in January 2026, and consequently, the guidelines will start to apply on 28 July 2026. The legal basis is Article 81 of the MiCA Regulation, which requires CASP employees who provide information or advice on crypto-assets to possess appropriate knowledge and competence.

This is not a 'yesterday's event' but an anticipated deadline - 11 days from today. We include it as a watchlist item, rather than as fresh news.

To Whom It Applies

The guidelines apply to all licensed CASPs across the EU/EEA - regardless of size, number of users, country of licence issuance, or the type of services provided. ESMA distinguishes between two staff functions: those who provide information on crypto-assets and services, and those who provide advice (e.g., personalised recommendations or portfolio management). The minimum requirements for knowledge, experience, and professional qualifications are higher for the second group.

ESMA sets qualitative criteria - a minimum level of knowledge, relevant experience, and continuous professional training, taking into account the specificities of crypto markets (high volatility, cybersecurity risks). Specific volumes (e.g., training hours per year) are clarified by national supervisors, who integrate the guidelines into their supervisory practice based on the 'comply or explain' principle. Competent authorities were required to notify ESMA of their compliance status within two months of the publication of the guideline translations.

What This Means for Baltic and Nordic Exchanges

Practically, this affects every company in the region that has already obtained a MiCA CASP licence or is awaiting one: in Latvia (Latvijas Banka), Lithuania (Lietuvos bankas), Estonia (Finantsinspektsioon), Finland (Finanssivalvonta), Sweden (Finansinspektionen), Norway and Denmark (Finanstilsynet). Each supervisor must confirm how it applies the ESMA guidelines, and CASPs must be able to provide documentation of staff's initial competence assessment, training, and its periodic updating.

For licensed players in the region - such as Sweden's Safello, Norway's TYR Markets, Denmark's Penning, as well as exchanges licensed in the Baltics - it is advisable to ensure by 28 July that customer support, onboarding, and advisory staff have documented competence. For firms still in the licensing process, this requirement becomes part of supervisory expectations from day one of operation.

Context - A Reminder, Not Fresh News

The first major deadline of the MiCA transitional period ended on 1 July 2026: unlicensed service providers had to cease serving EU clients, and several global platforms (including Binance) announced their withdrawal from the EU market. In Lithuania, where around 850 crypto companies were once registered, only a few firms have obtained a licence - industry consolidation continues. The 28 July knowledge and competence deadline is the next specific MiCA 'second-level' checkpoint after 1 July.

Separately, in the field of hardware wallets, on 9-10 July, the public discussion between Ledger and Tangem continued regarding a laser fault-injection vulnerability in Tangem cards; Tangem described it as a laboratory-conditions, physical access scenario. We covered this topic in detail in the 13 July article, and there have been no new developments in this dispute over the past 24-48 hours.

Watchlist - Next Checkpoints

In the coming week, it is worth following: (1) 28 July - the start of the application of ESMA's knowledge and competence guidelines; (2) announcements from national supervisors regarding their integration (Latvijas Banka, Lietuvos bankas, Finantsinspektsioon, Finanssivalvonta, Finansinspektionen, Finanstilsynet); (3) new entries in the ESMA CASP register from Baltic and Nordic jurisdictions; (4) potential supervisory warnings regarding unlicensed service providers after the 1 July deadline.

Summary for Market Participants

Firstly, licensed CASPs must organise staff competence documentation by 28 July - initial assessments, proof of training, and an update schedule. Secondly, information and advisory roles must be distinguished, as they have different requirements. Thirdly, follow your national supervisor's precise interpretation, as this is where specific volumes are clarified. Fourthly, for users: when choosing an exchange, card, or wallet, preference should be given to service providers listed in the ESMA CASP register. Fifthly, editorial note: this is an explanatory article - not news about an event that occurred in the last 24 hours.

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