On 25 June 2026, the Central Bank of Ireland (the Central Bank) published the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Minimum Competency) (Amendment) Regulations 2026 (the 2026 Regulations).

The 2026 Regulations amend the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) Minimum Competency Regulations 2017 (the 2017 Regulations), which place obligations on firms regarding compliance with the Minimum Competency Code 2017 (the MCC). The MCC sets out minimum competency requirements for staff of regulated financial services firms performing certain controlled function roles, with particular emphasis on areas dealing with consumers (as defined).

With effect from 28 July 2026, the 2026 Regulations introduce a number of changes to the Minimum Competency Code framework. Some of these changes apply broadly across regulated firms, including expanding the definition of “consumer”, while others introduce specific competency requirements for firms providing crypto-asset services under the European Union’s Markets in Crypto-assets Regulation (MiCA). This article highlights the key changes and their practical implications for regulated firms.

Definition of Consumer

A change of general application is the update to the definition of consumer, which aligns the MCC with the revised definition in the Central Bank’s Consumer Protection Code 2025 (CPC 2025), which came into force in March 2026 (see our article here).

In line with the CPC 2025, a “consumer” is defined to include:

• a natural person,
• a group of natural persons, including a partnership, club, charity, trust or other unincorporated body, or
• an incorporated body that has an annual turnover under €5 million in the preceding financial year, or, in the case of an incorporated body that is a member of a group, a combined turnover of less than €5 million.

The revised definition brings more incorporated bodies (and groups) within the scope of the MCC, as the turnover threshold increases from €3 million to €5 million.

Extension of the MCC Regime to Crypto-Asset Services

The 2026 Regulations extend the MCC regime to individuals who give information or provide advice on crypto-assets or services under the MiCA. The amendments implement ESMA’s ‘Guidelines for the criteria on the assessment of knowledge and competence under the Markets in Crypto Assets Regulation‘ (the ESMA Guidelines), which apply from 28 July 2026. As noted in our recent article on MiCA-related developments (see here), these changes follow the Central Bank’s previously stated intention to incorporate the ESMA Guidelines into the MCC regime.

Under the new competency framework, firms providing crypto-asset services (CASPs) must:

• include information on their internal accredited persons register relating to the qualifications and appropriate experience of those performing services relating to MiCA; and
• remove a person performing MiCA services from the register where they have failed to meet the CPD requirements prescribed in the MCC for the past 5 years.

Where an individual performs a relevant controlled function for the first time and does not yet hold a recognised qualification (a “new entrant”), CASPs must:

• agree a plan with the individual so that they can gain the relevant qualification and experience and ensure that they undertake an internal training programme relevant to the function; and
• ensure that an appropriately qualified person checks and approves all documents relating to the performance of the role by the new entrant until they obtain the relevant qualification and experience.

As part of their annual internal review, CASPs must verify that individuals performing MiCA services hold an appropriate qualification. CASPs are also required to review their policies and procedures at least once a year to ensure compliance with the MiCA Regulation and the ESMA Guidelines.

Updates to MCC Q&A

Alongside the 2026 Regulations, the Central Bank updated its MCC Q&A to address crypto-asset services and provide additional clarification on the application of the MCC regime.

The MCC Q&A clarifies, among other things, that:

• the 2017 Regulations (as amended) apply to CASPs;
• individuals cannot ‘grandfather’ previous professional experience for crypto-asset services;
• individuals giving information on crypto-assets or services must complete a minimum of 10 hours of CPD each year;
• individuals providing advice on crypto-assets or services must complete a minimum of 20 hours CPD each year;
• transitional arrangements apply to existing staff who provide information or advice on crypto-assets or crypto-asset services, where a CASP determines that they possess the knowledge and competence required under the updated MCC regime.

Conclusion

Firms should review the amendments introduced by the 2026 Regulations and assess their impact on existing competency frameworks, training arrangements, CPD processes and accredited persons registers. CASPs should pay particular attention to the new qualification, competency and governance requirements applicable to MiCA-related activities.

Should you have any queries on this topic, please contact a member of our Insurance & Reinsurance team, or your usual William Fry contact.