MiFID II in Ireland: What Investment Firms Expect From Staff Knowledge and Competence

If you run or work in an investment firm authorised in Ireland under MiFID II, one question comes up in every supervisory conversation about people: can the firm show that the staff advising and informing clients actually know enough and are competent to do it? This guide sets out what the Central Bank of Ireland and ESMA say on staff knowledge and competence, and how the Irish Minimum Competency framework fits in. It also links to our guide to the Central Bank fitness and probity regime, which deals with a different, though related, test for senior roles.

This is a reading guide to published material, not legal advice. Where we give figures, we say which document they came from and its date. Rules in this area have been amended several times, so check the current Central Bank and ESMA pages before relying on any detail.

What the Central Bank says about MiFID firms

The Central Bank's page introducing MiFID investment firms describes MiFID II as the EU framework governing the provision of investment services in financial instruments, and says the Central Bank is responsible for the prudential regulation and supervision of MiFID investment firms authorised in Ireland. On people and governance, the page says:

• MiFID II brings stricter governance requirements, and qualified senior management and directors must commit sufficient time to perform their functions.
• The compliance officer's role is enhanced, and compliance officers must ensure that staff selling or advising on MiFID financial instruments understand the compliance requirements under MiFID II.
• There are stricter remuneration controls for staff advising or selling to clients, which the page links to acting in clients' best interests.

The page does not show a last-updated date. A companion page on regulatory requirements and guidance for MiFID firms lists the Minimum Competency Code under the heading "Consumer Protection", and lists corporate governance requirements, a themed assessment of compliance functions dated 18 May 2026 and other supervisory material. We have not summarised that themed assessment here, and firms should read it directly.

The ESMA guidelines on knowledge and competence

The detailed EU-level picture comes from ESMA's guidelines for the assessment of knowledge and competence (document dated 3 January 2017). The guidelines say they were issued under the ESMA Regulation and are required by Article 25(9) of MiFID II, which concerns the knowledge and competence criteria referred to in Article 25(1). They apply from 3 January 2018 and are addressed both to national competent authorities and to firms.

Who counts as staff

Under the guidelines, "staff" are natural persons, including tied agents, who give investment advice or provide information to clients about financial instruments, investment services or ancillary services. The guidelines say some roles fall outside scope, such as staff who only point clients to sources of information, hand out brochures without explaining them, or do back-office work with no client contact.

Qualification and experience

The guidelines say knowledge and competence requires both an appropriate qualification and appropriate experience. Experience means demonstrated ability through previous work, assessed on a full-time equivalent basis, with a minimum of six months, which an authority may extend. The guidelines set a higher standard for staff giving advice than for staff who only provide information. For advice staff the criteria include suitability assessment, diversification and the effect of markets and economic events on the value of products. For information staff they include product risks and costs, how markets function, the limits of past performance as a guide, and awareness of market abuse and anti-money laundering issues. Authorities may set higher standards than these minimums.

Supervision of people who are not yet fully qualified

Staff who lack the qualification, the experience or both may work only under supervision. The guidelines say the supervisor must hold both an appropriate qualification and appropriate experience, must tailor the supervision to the services the staff member provides (for example supervision during client meetings and of calls and e-mails), and bears responsibility for the service, including signing off suitability reports where advice is given. Supervision may last a maximum of four years unless the authority sets a shorter period.

What the guidelines say firms should do

The guidelines set out organisational expectations for firms (phrased as "should"). They should clearly define responsibilities and distinguish advice roles from information roles, assess staff against the criteria, and review staff development and experience needs at least annually. They should also require continuing professional development, with specific training before new investment products are offered, and keep records of staff knowledge and competence that can be given to the authority on request. The compliance function should review adherence and report to the management body. An annex gives illustrative practices such as regular mandatory training and a code of ethics acknowledged in writing, but the guidelines present these as examples, not binding steps. The guidelines set no fixed number of training hours.

How Ireland applies it: the Minimum Competency framework

In Ireland, the Central Bank's Minimum Competency Code 2017 and Minimum Competency Regulations 2017 are the main domestic framework. The Central Bank's Q&A document on the Code (cover marked "Updated June 2026") states that the ESMA guidelines on knowledge and competence were implemented through the 2017 Code and Regulations. According to that document:

• Part 1 of the Code covers certain MiFID services provided to retail clients, and retail clients who elect professional status. Part 2 covers per se professional clients. Q&A 3.5 notes that Part 2 can also apply to some MiFID services given to retail and elective professional clients, so check which Part applies to your activity.
• The Q&A says the standards in the Code apply to persons exercising certain controlled functions within firms. Obligations are based on activities, not job titles.
• A regulated firm must ensure that persons performing relevant functions on its behalf comply with the Code, and the Regulations require firms to ensure those persons have appropriate competence and skills through training or experience.
• The Q&A says an annual review of an employee's qualifications and development and experience needs was introduced in the Minimum Competency Regulations 2017; it says the information does not need to be included on the Minimum Competency register, although the register may need to be amended after the review.
• Ongoing CPD is addressed across several answers. The document states a general requirement of 15 hours a year, with at least one hour on ethics, and says CPD hours must be accredited by the provider of a recognised qualification or by a professional educational body. Requirements differ for particular roles, so confirm which answer applies to yours.

The Central Bank's Minimum Competency page adds that, from 28 July 2026, the framework also covers knowledge and competence requirements for staff of crypto-asset service providers. That is a reminder that scope changes over time and that firms should check the page for the current position. For a fuller look at the CPD side, see our guide to Minimum Competency Code CPD requirements.

Competence is not only about frontline advisers

The Q&A document also says that, under the Central Bank Reform Act 2010, firms must ensure persons in controlled functions meet the Fitness and Probity Standards. Competence for client-facing staff and fitness and probity for controlled functions are separate regimes, and an individual may be caught by both. The Central Bank's 2021 guidance note for authorisation as a MiFID investment firm shows how this plays out at the start: applicants must address how the Minimum Competency Code applies to their activities, their compliance manual should cover staff training, and their board must include a balance of executive and non-executive directors with a statement on its collective suitability.

The accountability of senior individuals is a further, separate topic. Our guide to the Individual Accountability Framework covers that regime. We have not covered how it interacts with MiFID roles in this article.

A practical approach for firms

Our suggestion: use the following as a working checklist. It is our reading of the published material, not a Central Bank requirement.

• Map roles to activities. Because the Code works by activity and not job title, list each role and note whether it advises, informs or does neither.
• Keep a competence matrix. For each person, record qualification, experience, any supervision arrangement and supervisor, and review dates.
• Diary the annual review. Both the ESMA guidelines and the Central Bank Q&A refer to an annual review of qualifications and development needs, so schedule it and keep a short note of the outcome.
• Train before you launch. The guidelines refer to specific training before new products are offered, so make that a step in your product approval process.
• Make evidence retrievable. The guidelines say records must be available to the authority on request, so keep them in one place.
• Check new joiners and supervised staff. Make sure a supervised person's supervisor is qualified and experienced, and that a supervision end date is tracked.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Does MiFID II set a specific qualification for advisers in Ireland?

The ESMA guidelines require an appropriate qualification and appropriate experience and leave detail to national authorities. In Ireland the Central Bank's Minimum Competency Code and Regulations 2017 implement those guidelines. We have not reproduced the list of recognised qualifications here, so check the Central Bank's Minimum Competency page and the Code itself for the current position.

Can someone without the full qualification advise clients?

According to the ESMA guidelines, staff without the necessary qualification or experience may work only under supervision by a suitably qualified and experienced person, for a maximum of four years unless the authority sets a shorter period. Under the guidelines, a staff member who lacks the necessary knowledge and competence cannot provide the relevant services, other than under supervision where that applies.

Who is responsible for checking staff competence?

The firm. The Central Bank's Q&A states that a regulated firm must ensure persons performing relevant functions on its behalf comply with the Code. The ESMA guidelines also say the compliance function should review adherence and report to the management body.

How often should a firm review staff knowledge and competence?

The ESMA guidelines refer to a review of staff development and experience needs at least annually, and the Central Bank's Q&A refers to an annual review of qualifications and development needs.

Is back-office staff covered?

The ESMA guidelines say staff doing back-office work with no client contact are outside their scope. The Central Bank's Code applies by reference to in-scope activities, so check the Q&A document for your specific function.

Review these Central Bank and ESMA pages at least once a year, and whenever your firm adds a new service or product, so that your competence records keep pace with the rules.