Kenya VASP capital requirements 2026: the full LN 134 table

Kenya Published 2026-08-10 · updated 2026-08-13

One table decides whether you can apply at all

Kenya’s Virtual Asset Service Providers Regulations, 2026, gazetted as Legal Notice No. 134, set tiered prudential requirements by licence category in the Fifth Schedule. For most operators the capital line is the first genuine go or no-go in the whole exercise: everything else in an application can be built, but paid-up capital either exists or it does not.

The gazetted figures came in substantially below the March draft. Several categories were cut by 80 to 95 per cent, and the minimum capital requirement for investment advisers was removed altogether. Firms that shelved a Kenya plan on the basis of the draft numbers should look again.

The capital table

Minimum paid-up capital by licence category, as reported from the gazetted Fifth Schedule:

• Fiat-referenced stablecoin issuer — KES 300 million
• Virtual asset wallet provider — KES 150 million
• Virtual asset exchange — KES 100 million
• Initial coin offering provider — KES 20 million
• Token issuance platform — KES 20 million
• Virtual asset manager — KES 20 million
• Virtual asset broker — KES 10 million
• Tokenisation provider — KES 10 million
• Virtual asset payment processor — KES 10 million
• Virtual asset investment adviser — no prescribed minimum

Updated 13 August 2026: these figures have now been checked against the gazette itself — Kenya Gazette Supplement No. 185 (Special Issue 4253), Legislative Supplement No. 103, Legal Notice No. 134 of 22 July 2026 — and every one of the ten is confirmed. They are no longer secondary reporting. The Fifth Schedule is titled "Capital and Liquidity Requirements" and is cited to rr. 6(2)(h), 85(2)(a), 85(3) and 85(12). It carries no fee column and no insurance column; fees sit in the First Schedule and insurance in regulation 88.

Stablecoin issuers carry a second test

The KES 300 million paid-up figure is not the whole prudential requirement for stablecoin issuance. Issuers must also maintain minimum liquid capital of KES 60 million, or 100 per cent of current liabilities for at least thirty days, whichever is higher — alongside full reserve-backing obligations on the tokens themselves.

That structure matters more than the headline number. Paid-up capital is a one-time raise; a liquid capital floor expressed as a proportion of current liabilities scales with the business and has to be monitored and reported continuously. A stablecoin book that grows quickly can breach the liquidity test long before anyone thinks to revisit the capital position.

Two regulators, and the split is by activity

Kenya did not create a single crypto regulator. Supervision is divided by the nature of the activity:

• Central Bank of Kenya — wallet providers, payment processors and stablecoin issuers. Broadly, the payment and money-like side.
• Capital Markets Authority — exchanges, brokers, investment advisers, virtual asset managers, initial coin offering providers, tokenisation businesses and token issuance platforms. Broadly, the investment and market-infrastructure side.

A firm running an exchange that also custodies client wallets is not choosing between two supervisors. It is likely dealing with both, and it needs to capitalise for both licence lines rather than for whichever is cheaper. That is the single most common costing error we see in early-stage Kenya plans.

How capital interacts with the deadline

The Virtual Asset Service Providers Act commenced on 4 November 2025, which makes 4 November 2026 the transition deadline for providers already operating in Kenya. There is no transitional relief — no grandfathering, no provisional operating permission while an application sits in a queue.

Read against the capital table, that has a hard practical consequence. Paid-up capital is not something an applicant can promise to inject once the licence is granted. It has to be subscribed, paid and evidenced as part of the application, which means the board approval, the transfer, the bank confirmations and the statutory filings all need to happen before you file, not after. For a foreign parent funding a Kenyan subsidiary, add time for the transfer, the source-of-funds evidence and the audit trail the regulators will expect.

Counting backwards from 4 November 2026, a firm that has not resolved how it will fund a KES 100 million or KES 150 million requirement is already behind.

What the table does not tell you

Minimum capital is a threshold, not a budget. It sits alongside fit-and-proper requirements for directors and significant shareholders, AML and CFT frameworks, technology and cybersecurity controls, conduct rules and ongoing reporting. Advisers escape a capital minimum but not the rest of the regime, and other prudential conditions in the Fifth Schedule — including insurance requirements — should be checked category by category against the notice rather than assumed from a summary.

Practical next steps

• Map every activity you carry on in or into Kenya to a licence category, then apply 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. It is not the sum, and it is not the highest alone.
• Identify which regulator each category sits with, and plan for parallel engagement where you span both.
• If stablecoin issuance is in scope, model the liquid capital test against projected liabilities, not just the KES 60 million floor.
• Start the funding and evidence trail now — the money must be in and documented before the application, not after.
• Verify every figure above against the Fifth Schedule to Legal Notice No. 134 before you commit capital.

The liquid capital column, which is rarely reported

The Fifth Schedule has two columns, not one. The second — liquid capital — is where most published summaries stop, and it is the column that scales with the business. Transcribed from the gazette:

• Wallet provider — KSh 30,000,000 or 100% of current liabilities for at least 30 days, whichever is higher
• Exchange — KSh 20,000,000 or 8% of total liabilities, whichever is higher
• Payment processor — 100% of current liabilities for at least 30 days. Note there is no floor at all on this line.
• Broker — KSh 2,000,000 or 8% of total liabilities, whichever is higher
• Investment advisor — NIL
• Virtual asset manager — KSh 4,000,000 or 8% of total liabilities, whichever is higher
• Initial coin offering — KSh 4,000,000 or 8% of total liabilities, whichever is higher
• Tokenization — KSh 2,000,000 or 8% of total liabilities, whichever is higher
• Token issuance platform — KSh 4,000,000 or 8% of total liabilities, whichever is higher
• Stablecoin issuance — KSh 60,000,000 or 100% of current liabilities for at least 30 days, whichever is higher

The 8 per cent limb bites earlier than the floors suggest. For a broker or a tokenisation provider, the KSh 2 million figure stops being the answer at roughly KSh 25 million of total liabilities, after which the percentage governs. An operator reading only the paid-up column has not finished the calculation.

One further rule that changes the arithmetic for combined models: under 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 for each additional activity. An exchange that also custodies wallets is therefore at KSh 150m + KSh 50m = KSh 200m — not KSh 150m, and not KSh 250m. Regulation 85(7) also lets the authority raise the requirement by risk profile, so the schedule figure is a floor rather than a ceiling.

The checklist behind this article

Everything above is drawn from the same working document I use when I read a file: an 11-page readiness checklist for VASP licensing in Kenya, covering the CBK/CMA split by activity, the full paid-up capital table from the Fifth Schedule to Legal Notice 134, the stablecoin liquid-capital test, the evidence trail that has to exist before you file, the fee schedule, and the points that are still genuinely open. Every figure is marked with whether it comes from the instrument or from reporting of it — because planning against a secondary figure is sensible and capitalising against one is not. It is USD 79, and buyers get the updated edition free when the application window opens.

If your situation is straightforward, the checklist is genuinely enough and you will not need to speak to me. If it is not, the 48-hour gap check reads what you have and returns a written list of what is missing, in the order it should be fixed.