What a Kenya VASP application costs, and what goes in it
Kenya's Virtual Asset Service Providers Regulations, 2026 — Legal Notice No. 134, made on 3 July 2026 and published in Kenya Gazette Supplement No. 185 (Special Issue 4253), Legislative Supplement No. 103, of 22 July 2026 — put the licence fees in the First Schedule. The Schedule is cited to regulations 5(1), 6(2)(u), 7, 11(3)(b), 13(1), 29(2), 49(2)(g), 61(2)(c) and 62(2)(h).
Most published Kenyan commentary quotes the capital figures and skips the fees. They are worth knowing early, mainly because they are small enough to be the wrong thing to plan around.
Two fees, not one
Every category carries an application fee payable when you file and a separate licence fee payable on grant. Figures below are from the gazetted First Schedule, in Kenya shillings, as application fee | licence fee:
- Virtual asset wallet provider — 100,000 | 500,000
- Virtual asset exchange — 100,000 | 1,000,000
- Virtual asset payment processor — 100,000 | 200,000
- Virtual asset broker — 100,000 | 100,000
- Virtual asset investment adviser — 10,000 | 50,000
- Virtual asset manager — 50,000 | 200,000
- Initial coin offering provider — 100,000 | 500,000
- Tokenisation provider — 100,000 | 500,000
- Token issuance platform — 100,000 | 500,000
- Fiat-referenced stablecoin issuer — 100,000 | 2,000,000
The spread on the application side is narrow: nine of the ten categories cost the same KSh 100,000 to file. The differentiation is all on grant, and again at renewal.
Renewals are turnover-linked, and that is the part to model
Renewal is not a flat repeat of the licence fee for most categories. Under the First Schedule a wallet provider renews at KSh 500,000 or 0.15 per cent of gross turnover, whichever is higher; an exchange at 500,000 or 0.5 per cent of prior-year gross revenue, whichever is higher; ICO, tokenisation and token issuance platform licences at 500,000 or 0.15 per cent of gross turnover; and a stablecoin issuer at 2,000,000 or 0.15 per cent of gross turnover. A virtual asset manager renews at 0.05 per cent of assets under management, with a floor of 200,000 and a ceiling of 5,000,000. Brokers (100,000) and advisers (50,000) are flat.
Payment processors sit on an annual turnover band instead: 20,000 up to KSh 1 billion; 100,000 from 1 to 10 billion; 500,000 from 10 to 50 billion; 1,000,000 from 50 to 100 billion; 5,000,000 from 100 to 500 billion; 10,000,000 from 500 billion to 1 trillion; and 15,000,000 above 1 trillion.
For a business at any scale, the percentage limb is the operative one. Model it against your own forecast rather than quoting the headline number to your board.
The approval fees that arrive later
- Approval of an initial coin offering, and approval of a virtual asset tokenisation: 0.25 per cent of the value of the successful offer, subject to a minimum of KSh 200,000 and a maximum of KSh 30,000,000.
- Approval of a proposed acquisition, transfer or disposal of shares in a licensee: 0.25 per cent of transaction value or KSh 50,000, whichever is higher. This one catches funding rounds.
- Approval of the assignment or transfer of a licence: the licence fee for that category.
What the fee actually buys you the right to file
Regulation 6(2) sets the contents of the application, and the fee is only item (u) in it. Two parts of the pack take longer to build than anything else:
- Regulation 6(2)(f) requires written operational policies — nine of them in the gazetted text: risk management; AML/CFT/CPF; data protection and privacy; cybersecurity and information technology; complaints management; market conduct; consumer protection; conflict of interest; and business continuity and disaster recovery. The provision says "including", so the list is a floor. The four-item list still circulating in summaries comes from the National Treasury's March 2026 draft, not from the law.
- The Third Schedule business plan requires a named risk register identifying key risks. It is a deliverable in the application, not an annex to be produced later, and in practice a reviewer reads the register before the prose.
Regulation 6(2)(h) ties the application to the Fifth Schedule capital and liquidity requirements, and the Second Schedule carries the application form itself.
Fees are not the cost driver. Capital is
Set the fees against the Fifth Schedule and the proportions are obvious: KSh 100,000 to apply as an exchange, against KSh 100,000,000 of paid-up capital to qualify.
The provision to read carefully is regulation 85(6). A licensee undertaking more than one permissible activity holds the paid-up capital of the highest-capital category plus fifty per cent of the paid-up capital for each additional activity. Not the sum, and not the highest alone. An exchange plus a wallet is KSh 150,000,000 plus 50,000,000 — KSh 200,000,000. Regulation 85(7) then lets the authority raise the requirement by risk profile, so the Schedule is a floor rather than a ceiling. Insurance is separate again, in regulation 88.
What is still open
As at 14 August 2026 the application window had not opened and the form had not been published. Two questions that affect sequencing remain unanswered in the instrument: whether an applicant that has filed but not been determined by the 4 November 2026 deadline may keep operating, and how the regulation 85(7) uplift will be applied in practice. The deadline itself comes from section 47 of the VASP Act 2025 (Act No. 20 of 2025), and there is no transitional provision, no savings clause and no deemed-licensing regulation anywhere in the 151 regulations.
The checklist behind this article
Our Kenya VASP readiness checklist maps each requirement to its regulation, marks every figure as gazette text or as reporting of it, distinguishes the March 2026 draft from Legal Notice 134 throughout, and leaves the open questions above marked open rather than guessed. USD 79, with the updated edition free as the position develops.
If you are applying in a single category, the checklist covers the ground on its own. If you are stacking activities and need the regulation 85(6) arithmetic worked against your own structure, the 48-hour gap check is the faster route.