Updated 8 August 2026 · Virtual Asset Service Providers Act 2025 · Legal Notice 134 of 2026
Kenya's Virtual Asset Service Providers (VASP) regulations were gazetted on 22 July 2026 as Legal Notice 134 of 2026. The single most important change from the March 2026 draft is capital: the minimum paid-up figures fell by up to 95%. If your business case was shelved because the capital looked impossible, it changed under you.
| Category | Draft (Mar 2026) | Gazetted (Jul 2026) | Regulator |
|---|---|---|---|
| Tokenisation provider | KES 200m | KES 10m (−95%) | CMA |
| Payment processor | KES 50m | KES 10m (−80%) | CBK |
| Broker | KES 30m | KES 10m (−67%) | CMA |
| Initial coin offering | KES 200m | KES 20m (−90%) | CMA |
| Token issuance platform | KES 200m | KES 20m (−90%) | CMA |
| Virtual asset manager | KES 30m | KES 20m (−33%) | CMA |
| Exchange | KES 150m | KES 100m (−33%) | CMA |
| Wallet provider | KES 150m | KES 150m (unchanged) | CBK |
| Stablecoin issuer | KES 500m | KES 300m (−40%) | CBK |
| Investment adviser | KES 2.5m | Exempt* | CMA |
Figures are cross-checked across four press reports; the Fifth Schedule text is not yet verified line-by-line against Kenya Gazette Supplement No. 185. Treat as high-confidence, not certified. 1 KES ≈ USD 0.0078.
Investment advisers are exempt from the minimum-capital requirement, but must carry professional indemnity cover of at least KES 1,000,000. PI underwriting takes weeks; on a calendar basis this can be harder than raising capital. The cheapest-looking category is not always the fastest to clear.
For tokenisation and initial coin offerings, liquid capital is the higher of a flat figure (KES 2m and KES 4m respectively) or 8% of total liabilities. Once liabilities pass about KES 25m, the 8% limb overtakes the flat figure. Costing against the paid-up line alone understates your requirement.
Wallet providers, payment processors and stablecoin issuers are supervised by the Central Bank of Kenya. Exchanges, brokers, token-issuance platforms, offerings, tokenisation providers, asset managers and advisers sit with the Capital Markets Authority. Read yourself onto the correct side before anything else — it sets your capital figure, and the figures differ by up to fifteen times.
Existing providers must be licensed by 4 November 2026. There is no transitional provision. Note the asymmetry: the application process has not yet opened, so you cannot file — but the deadline has not moved. Prepare now; file the day the window opens.
Get the 34-point checklist (PDF, USD 79)48-Hour Gap Check on your entity (USD 500)
This is a compliance-readiness aid, not legal advice and not a filing service. Regulations may change. TK Global OS — Okinawa, Japan.