Kenya's 4 November 2026 VASP deadline, explained
Kenya's Virtual Asset Service Providers Act 2025, together with Legal Notice 134 of 2026, sets a hard date: existing providers must be licensed by 4 November 2026. The Act contains no transitional provision — there is no grandfathering and no run-off. Operating unlicensed after that date is an offence.
The asymmetry to plan around
As at writing, the licensing process has not yet opened for applications. Of the firms that have publicly committed to applying, none has been able to state a filing date. You cannot file yet — but the deadline has not moved. The firms that prepare now will be ready the day the window opens.
Settle your regulator first
Read yourself onto the correct side of the line before anything else, because it sets your capital figure:
- CBK supervises wallet providers, virtual-asset payment processors and stablecoin issuers.
- CMA supervises exchanges, brokers, token-issuance platforms, ICOs, tokenisation providers, virtual-asset managers and investment advisers.
Then confirm your capital
The gazetted figures cut the March 2026 draft by up to 95%. Stablecoin issuers face KES 300m paid-up; wallet providers KES 150m; tokenisation KES 10m; ICOs KES 20m; investment advisers are exempt from minimum capital but must carry professional-indemnity cover of at least KES 1,000,000. Confirm the exact figure for your category against the Fifth Schedule of the gazette before you rely on it.
What to do now
- Fix your category (CBK vs CMA) and cost your capital against it.
- Draft the nine operational policies required under r.6(2)(f) as gazetted — risk management; AML/CFT/CPF; data protection and privacy; cybersecurity and IT; complaints management; market conduct; consumer protection; conflict of interest; and a business continuity and disaster recovery plan. The four-item list still circulating comes from the March 2026 draft, not the law. Each needs a board meeting to approve.
- Line up audited financials, source-of-funds evidence and your Kenyan entity, office and bank account.
- Run a gap analysis so the longest-lead item is identified with weeks to spare.
Updated 12 August 2026.
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.