The CNMV does not ask how many courses you have paid for. It asks who provides information, who gives advice and what evidence backs each one. We build the role map, the staff matrix and the individual files that support your answer.
Do you need to prove your team’s qualifications?
Tell us how many people deal with clients and what each one does: we will tell you what is missing for your file to hold up.
The requirement is not met with a certificate in a drawer. It is met with a system that shows who does what, with what qualification and since when.
The document that organizes everything: the definition of roles, the requirements for each one, the rules for staff in training, the annual plan, assessment and the person responsible for the process. Approved by the management body and version-controlled.
The CNMV publishes the list of verified qualifications and certificates. We check which of them actually cover the role of each person on your team, and what to do about staff who prove their training by other means.
We audit the staff matrix against reality: who deals with clients today, what they can prove and what is missing before a supervisory review.
The qualifications of your sales network and those of your board are separate assessments, with separate files. It is best not to mix them.
The annual AML/CFT plan is a separate obligation with a separate register. We plan them together so you do not duplicate sessions or evidence.
Staff qualification is one more permanent obligation, with its own calendar and periodic review.
Four different situations with one thing in common: someone has to be able to prove, person by person, that whoever talks to the client knows what they are talking about.
“We have people in several offices, and I cannot say how many only provide information and how many actually give advice. If someone asked me tomorrow, I would have to improvise the answer.”
“There are only a few of us and we all do a bit of everything. The problem is that ‘a bit of everything’ includes recommending products, and that requires a qualification that not all of us have documented.”
“Every new hire arrives without a certificate and starts dealing with clients in the first month. We need supervision rules that are in writing and do not depend on whoever happens to be the manager on shift.”
“The programme of operations has to describe our human resources. I want to present the team’s qualifications fully settled and not get a request for information on that section.”
CNMV Technical Guide 4/2017 sets different guideline hours depending on each person’s actual role. The role is measured by what the person does, not by what their business card says.
Misclassifying people: recording as “staff who provide information” someone who in fact recommends specific products. The CNMV looks at the conversation with the client, not the organization chart, and that is where the bar goes up.
A certificate without a file: having the diploma but not the record linking person, role, date and content. Without that matrix, every answer to a request for information becomes a race against the clock.
Forgotten ongoing training: the initial qualification does not expire on its own, but without documented annual updates it no longer proves anything when new products or regulatory changes come along.
| Role | Guideline hours | What you must be able to prove |
|---|---|---|
| Staff who only provide information | 80 hours | Content covered, assessment passed and a description of the actual role in the person’s record. |
| Staff who give advice | 150 hours | A qualification or certificate verified by the CNMV, or equivalent proven training, together with documented practical experience. |
| All qualified staff | Annual ongoing training | An annual plan, recorded attendance, assessment and updates when new products or regulatory changes arise. |
We map who provides information and who gives advice in your firm, review what each person can prove, close the gaps through training or by reassigning roles, and leave you with a staff matrix and individual files that answer a request for information on their own.
That the firm ensures, and can prove, that the people who provide information or give advice to clients on financial instruments have the knowledge and competence they need to do so. The standard is developed in the ESMA guidelines on knowledge and competence, and in Spain it is set out in CNMV Technical Guide 4/2017.
The obligation lies with the firm, not the employee. That is why what gets examined is not one person’s diploma, but the whole system: which roles exist, what each one requires and what evidence proves it.
CNMV Technical Guide 4/2017 gives general guidance: 80 hours for staff who only provide information and 150 hours for those who give advice, plus annual ongoing training for both.
Read this carefully: these are guideline hours, not a fee you pay once. What counts is that the content covers the required subjects, that there is an assessment and that the training fits the product range and type of client that person deals with. A hundred hours on subjects your firm does not market prove very little.
The CNMV publishes a list of verified qualifications and certificates: they are the cleanest route because their content has already been checked. But it is not the only one. A firm can prove its staff’s qualifications by other means, provided it documents content, hours, assessment and the person responsible, and that this documentation can withstand a review.
The usual mistake is the opposite: buying the cheapest certification without checking whether it covers the person’s actual role. Before you buy training, check the list of verified certifications and compare it with your role map.
Yes, but under the supervision of qualified staff and for a limited period, on the terms set by the technical guide. And the supervision has to be real and documented: who supervises whom, on which transactions and with what review.
The typical failure is treating it as a verbal formality. If there is no written appointment of the supervisor, no record of the reviews and no end date for the period, what the regulator sees is an unqualified person dealing with clients without any control. That finding is costly and easy to avoid.
An individual file with six items: a description of the actual role (providing information or giving advice, on which range and to which type of client), the qualification or certificate with its date, the content and hours completed, the assessment passed, ongoing training for each year and, where applicable, the supervision arrangements while the person was not yet qualified.
All of this is brought together in a staff matrix that lets you answer the most uncomfortable question at a glance: show me who gives advice today and what each of them can prove. If your matrix does not exist or is out of date, that is the first job.
Technical Guide 4/2017 provides for annual ongoing training. The firm must plan it, deliver it, assess it and keep a record of all of it.
Our practical recommendation is to approve a written annual plan at the start of the year, link it to the year’s actual changes (new products, regulatory developments, audit findings, complaints received) and close the year with a short implementation report to the management body. That report is the proof that the system is alive, and it is what separates a training plan from a list of courses.
No, and it is best not to mix them up. Knowledge and competence requirements apply to those who deal with clients, whether they provide information or give advice. The fit and proper assessment applies to those who run the firm: directors and general managers, who are assessed on good repute, knowledge and experience for the position.
They are two separate files, with different criteria and different evidence, even though one person may appear in both. We cover it on our fit and proper assessment of senior management page.
It is a separate obligation with its own calendar: as an obliged entity, your firm must train its staff in AML/CFT every year and keep evidence of that training.
In practice the two are planned together (same calendar, same attendance register, same archive) but proven separately, because the authority asking is not the same. We cover it on our mandatory anti-money laundering training page. And if you want to check the overall state of your MiFID II conduct compliance, start with a MiFID II audit.
The goal is not to train: it is to be able to prove that you have trained the right person, in the right subjects, at the right time. This is the sequence.
Before you buy a single hour of training, you need to decide who provides information and who gives advice, using written criteria applied to the real conversation with the client. The level of requirements that follows depends entirely on this map.
We cross-check the map against what each person can prove today. Gaps are closed in two ways: through training or by reassigning roles. The second is faster and sometimes more honest about the reality of the team.
An approved policy, a living matrix, an annual ongoing training plan, written rules for new hires and periodic review. A system that is not updated stops proving anything as soon as your staff changes.
If you also want to check how training is applied in practice (client files, tests and recommendations), that work is a MiFID II audit. And if your firm has just been authorized, fit this block into your ongoing obligations.
The 10 conduct controls the CNMV expects to see working in an EAF or investment firm, with the typical evidence for each one. Ideal as a quarterly self-assessment with your team.
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These terms appear in the policy, in the matrix and in any request for information on staff qualifications. Defining them properly avoids half the problems.
The requirement that anyone who provides information or gives advice on financial instruments has the qualifications and experience needed to do so.
Explaining the features, risks and costs of products or services without making a personal recommendation addressed to that client.
Suggesting a specific financial instrument to a specific client. It triggers the highest level of requirements and the suitability test.
A CNMV document that puts the ESMA guidelines on knowledge and competence into concrete terms: content, guideline hours and ongoing training.
Qualifications and certificates whose content the CNMV has verified as adequate to prove the required qualification.
An annual update of knowledge linked to regulatory changes, new products and needs identified during the year.
Arrangements that allow someone who is not yet qualified to deal with clients under the supervision of qualified staff, for a limited time.
A single register that cross-references person, assigned role, proven qualification, date and ongoing training for each year.
An individual set of documents: certificates, content, hours, assessments and evidence of the ongoing training received.
Written criteria distinguishing who provides information and who gives advice, applied to each person’s actual activity and not to their job title.
An approved knowledge and competence policy, a functional organization chart and an individual record with the assigned role and its date.
Each person proves training appropriate to their role, using the guideline hours in CNMV Technical Guide 4/2017 as a reference.
A verified qualification or certificate, a program with content and hours, an assessment passed and internal validation that it is adequate.
An annual plan that is approved, delivered and assessed, linked to regulatory changes, new products and incidents identified during the year.
The approved plan, invitations, attendance register, materials, assessments and an annual implementation report.
Written arrangements for anyone not yet qualified, with a defined scope of tasks and a limited duration.
Appointment of the supervisor, scope of permitted tasks, record of reviews and end date of the period.
An identified person responsible for the process, periodic review of the system and reporting to the management body.
An up-to-date staff matrix, minutes of approval and review, and an archive retrievable by person and by year.
None of these can be fixed with a course. They are fixed by putting the system in order before anyone asks.
Your team’s qualifications are never looked at in isolation. They go together with the list of certifications verified by the CNMV, the fit and proper assessment of those who run the firm, the review of how training is applied in client files and mandatory anti-money laundering training.
Which qualifications and certificates the CNMV recognizes, and how to choose the one that truly covers each person’s role.
A different file and different criteria: the good repute, knowledge and experience of those who manage and run the firm.
It checks whether training translates into correct client files: suitability, costs, inducements and traceability.
The annual obligation to train staff as an obliged entity, with its own register and evidence.
If you want the full conduct framework, go to MiFID II compliance. If your firm is already authorized, review the rest of your ongoing obligations. And if the supervisor has already asked, start with CNMV supervision and inspection.
Tell us how many people in your firm provide information or give advice to clients and what training they can prove: we will check whether the file holds up.
Last updated: August 4, 2026
The knowledge and competence requirement is one of the few MiFID II obligations that is checked person by person. It originates in the ESMA guidelines on the subject, and its Spanish implementation is CNMV Technical Guide 4/2017, which gives guidance on the content and hours expected of staff who provide information and staff who give advice. What gets examined is not the firm’s good intentions on training, but its ability to prove, with documents and dates, that every person who deals with clients is qualified for the role they actually perform.
The whole system rests on a distinction that is simple to state and hard to apply. Providing information means explaining the features, risks and costs of a product without steering the client toward a specific one. Giving advice means making a personal recommendation on a specific instrument for that client, which triggers the suitability test and the highest level of requirements. The line is not drawn by the job title or the business card: it is drawn by what happens in the conversation. A salesperson who “only provides information” but ends up suggesting the fund that suits the client is giving advice, and the firm is answerable for that person being qualified to do so. That is why the first deliverable of this work is not training, but a role map with written criteria, tested against real cases and also applied to the branch network, phone support and anyone who monitors portfolios. Classifying correctly cuts costs (not everyone needs the top level) and eliminates the most common finding: people classified below what they actually do.
CNMV Technical Guide 4/2017 sets general guidance of 80 hours of training for staff who only provide information and 150 hours for those who give advice, plus annual ongoing training for both groups. These are benchmarks for content and effort, not a toll: what matters is that the subjects cover the products your firm markets and the type of client it serves, and that there is an assessment proving the training was effective. To make compliance easier, the CNMV publishes a list of verified qualifications and certificates, which is the cleanest route because their content has already been checked; you can find it on our MiFID II certifications page. It is not the only route: other equivalent training is acceptable, provided the firm documents content, hours, assessment and the person responsible, and can explain why it considers the qualification proven. And for those who are not yet qualified, it is possible to work under the supervision of qualified staff for a limited period, with a written appointment and a record of the reviews.
The initial qualification opens the door; what keeps it open is annual ongoing training. A plan that works has four features. It is approved by the competent body at the start of the year, not improvised in December. It is linked to the reality of the year: new products, regulatory changes, internal audit findings, complaints received and issues raised by the compliance function. It is assessed, because attendance without proof of learning does not prove knowledge. And it is recorded: invitations, attendance lists, materials and assessments archived so they can be retrieved by person and by year. The natural close is a short implementation report to the management body, recorded in the minutes, showing what was planned, what was done and what is still pending. That document is what turns a list of courses into a system, and it shows that the firm monitors its own qualifications instead of hoping nobody asks.
When the CNMV looks into this area, the question is always the same: show me who gives advice today and what each of them can prove. The useful answer is a living staff matrix (person, role, qualification, date, hours, assessment, ongoing training) backed by an individual file that survives the employee’s departure. Without it, every request for information turns into a search through personal folders and HR emails, and that search is a finding in itself. It is also important not to confuse this area with the fit and proper assessment of senior management, which assesses those who run the firm with different criteria and a different file, or with annual anti-money laundering training, which is planned alongside it but proven separately, as we explain in mandatory anti-money laundering training. Breaches of the conduct rules fall under the penalty regime of securities market legislation, which classifies infringements as minor, serious and very serious. If you want to know whether your system is really applied in practice, the way to find out is a MiFID II audit.
This content is for general information only and does not constitute legal advice. The legislation cited may have been amended after the update date shown: always check the version in force or contact us to analyze your specific case.
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