Kenya Crypto Licensing Approaches November 4 Deadline: No VASP Licence Register Yet

What to Know

• Kenya’s Virtual Asset Service Providers Act 2025 came into force on 4 November 2025.
• Existing virtual asset service providers were given a one-year grace period ending on 4 November 2026.
• Regulatory jurisdiction is split between the Central Bank of Kenya (CBK) for payment and currency-like functions and the Capital Markets Authority (CMA) for market and investment services.
• According to VASP Tracker, zero published VASP licence holders were identified on official public registers as of 2 November 2026.
• The framework divides digital asset activities across ten distinct licensing tiers, spanning exchanges, wallets, stablecoins, payment processing, tokenisation, and advisory.
• Gazetted as Legal Notice No.134 in July 2026, the final VASP Regulations gave operators approximately 105 days to build complete application files and meet capital requirements before the deadline.

Kenya’s Virtual Asset Service Providers (VASP) Act 2025 officially took effect on 4 November 2025. It granted existing digital asset businesses a strict one-year window to secure a license. In two days, on November 4, 2026, that transition period will end. 

The VASP Regulations, 2026 were gazetted as Legal Notice No. 134 on 22 July 2026. That left existing firms roughly 105 days to prepare applications. However, as of 2 November 2026, data from the VASP Tracker indicates that zero licensed VASPs have been published on official public registers.

Two Regulators Oversee the Market

Kenya’s VASP framework splits oversight between the Central Bank of Kenya  (CBK) and the Capital Markets Authority (CMA). The oversight is shared according to the core economic function of the digital asset service.

The CBK supervises entities that handle fiat-crypto conversions, payment processing, customer funds custody, and stablecoin issuance. This includes:

• Stablecoin Issuers
• Virtual Asset Wallet Providers
• Virtual Asset Payment Processors

The CMA governs secondary market liquidity, trading structures, investment products, capital raising, and token issuance. The CMA supervises:

• Virtual Asset Exchanges
• Virtual Asset Brokers
• Virtual Asset Investment Advisers
• Virtual Asset Managers
• Initial Coin Offering (ICO) Providers
• Token Issuance Platforms
• Virtual Asset Tokenisation Providers

Ten Licensing Categories and Their Requirements

Kenya’s crypto regulations map all commercial crypto activities into ten different regulatory buckets:

Notable Capital Requirements

The gazetted regulations impose explicit minimum paid-up capital thresholds to ensure financial soundness and operational resilience:

• Stablecoin Issuer: KSh 300 million (plus strict liquidity rules requiring at least KSh 60 million or 30 days of operational liabilities).
• Virtual Asset Wallet Provider: KSh 150 million.
• Virtual Asset Exchange: KSh 100 million.
• Virtual Asset Broker/Payment Processor: KSh 10 million.

Crypto Africa News previously noted that while the intention behind the capital requirements centres on consumer protection, they could potentially drive smaller crypto entities out of the country’s market and innovation spaces.

No Published Licence Register Identified

Data captured by the VASP Tracker as of 2 November 2026 revealed zero published VASP licence holders across the CBK and CMA public registers. The absence of an entry on a published register does not mean that regulators have rejected or ignored every pending application.

Under standard regulatory procedure, applications undergo thorough due diligence, background checks, independent system audits, and fit-and-proper evaluations before formal approval.

Many major local and international firms may currently hold active, in-review applications or conditional approvals that have not yet been listed on public-facing directory portals. In August, Crypto Africa News reported that multiple firms, such as Luno, VALR, Yellowcard, and Binance, had geared up to apply for and secure a licence in Kenya. 

What Foreign Exchanges and Local Businesses Should Consider

The VASP Act explicitly applies to any entity providing virtual asset services “in or from Kenya”.

It imposes local presence obligations on interested VASPs. To qualify for a licence, applicants must establish a locally incorporated Kenyan company, retain at least one director resident in Kenya, maintain local management presence, and open local bank settlement accounts.

Offshore exchanges and global platforms targeting Kenyan consumers cannot bypass compliance simply by operating without a physical office in Nairobi. Active marketing, servicing local fiat rails, or processing transactions for Kenyan IP addresses brings offshore operators squarely into Kenya’s legal perimeter.

Applicants must implement FATF Travel Rule protocols, maintain segregated customer accounts, enforce strict AML/KYC checks, submit independent cybersecurity penetration tests, and establish clear corporate governance.

What Happens After the Transition Period?

Once the transitional clock expires at midnight on 4 November 2026, operating a virtual asset business in Kenya without an active licence or explicit regulatory cover becomes a criminal offence under statutory law.

Unless the CBK or CMA issues explicit transitional extensions or provisional guidance, unlicensed operators face severe consequences, including statutory fines, executive liability, banking system de-risking, and potential court-ordered cease-and-desist mandates.

For businesses operating in Kenya, confirming compliance status with legal counsel or regulatory authorities is an immediate operational imperative.