Kenya VASP renewal fees: the recurring cost the guides leave out
Most cost guides stop at the application fee
Search for the cost of a Kenyan virtual asset service provider licence and you will find the same two columns everywhere: an application fee and a first licence fee. Those are real and they are in the First Schedule to the Virtual Asset Service Providers Regulations 2026, Legal Notice No. 134 of 2026 (gazetted 22 July 2026, Kenya Gazette Supplement No. 185, Legislative Supplement No. 103). An exchange pays KSh 100,000 to apply and KSh 1,000,000 for the licence. A stablecoin issuer pays KSh 100,000 and KSh 2,000,000. An investment adviser pays KSh 10,000 and KSh 50,000.
What almost nobody sets out is the third column. The First Schedule — which is invoked by regulations 5(1), 6(2)(u), 7, 11(3)(b), 13(1), 29(2), 49(2)(g), 61(2)(c) and 62(2)(h) — also fixes renewal fees, and for most categories the renewal is not a flat number. It is a formula. That is the figure that decides whether a Kenyan licence is affordable in year three, and it is only readable in the gazetted text.
Renewals are formulas, not flat fees
The pattern in the First Schedule, as gazetted, is a floor with a percentage running above it, and you pay whichever is higher:
- Wallet provider: KSh 500,000 or 0.15% of gross turnover, whichever is higher.
- Exchange: KSh 500,000 or 0.5% of prior-year gross revenue, whichever is higher.
- Stablecoin issuance: KSh 2,000,000 or 0.15% of gross turnover, whichever is higher.
- ICO provider, tokenisation provider and token issuance platform: KSh 500,000 or 0.15% of gross turnover, whichever is higher.
- Virtual asset manager: 0.05% of assets under management, subject to a minimum of KSh 200,000 and a maximum of KSh 5,000,000.
- Broker: KSh 100,000. Investment adviser: KSh 50,000. These two are flat.
Reporting has begun to notice the shape without the detail; a TechCabal piece of 24 August 2026 records that renewal fees for most categories are the higher of a flat fee or a percentage of gross annual revenue, but does not give the percentages. The percentages above are from the gazetted First Schedule.
Where the percentage overtakes the floor
The arithmetic is worth doing once, because it tells you at what size the licence stops costing a fixed amount:
- An exchange crosses from the KSh 500,000 floor to the 0.5% limb at roughly KSh 100 million of prior-year gross revenue.
- A wallet provider crosses from KSh 500,000 to the 0.15% limb at roughly KSh 333 million of gross turnover.
- A stablecoin issuer crosses from KSh 2,000,000 at roughly KSh 1.33 billion of gross turnover.
- A virtual asset manager is on the KSh 200,000 minimum below about KSh 400 million of assets under management, and hits the KSh 5,000,000 cap at about KSh 10 billion.
These are straightforward calculations from the schedule figures, not separate rules. But they change the conversation: a mid-sized exchange is not budgeting KSh 500,000 a year, and a manager at scale has a capped, predictable number that a percentage-only reading would overstate.
The payment processor ladder
Virtual asset payment processors are treated differently again. Their renewal is banded by annual turnover rather than expressed as a percentage: KSh 20,000 up to KSh 1 billion; KSh 100,000 from 1 to 10 billion; KSh 500,000 from 10 to 50 billion; KSh 1,000,000 from 50 to 100 billion; KSh 5,000,000 from 100 to 500 billion; KSh 10,000,000 from 500 billion to 1 trillion; and KSh 15,000,000 above 1 trillion. A payments business that grows through a band boundary sees its licence cost step, not drift.
Approval fees are a separate line entirely
Renewal is not the only recurring charge. The First Schedule also prices approvals, and these are the items that surprise transaction teams:
- Approval of an initial coin offering, and approval of a virtual asset tokenisation, each cost 0.25% 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 costs 0.25% of the transaction value or KSh 50,000, whichever is higher.
- Approval of the assignment or transfer of a licence costs the licence fee for that category.
The share-transfer figure in particular is worth flagging to founders and investors early. It is charged on transaction value, and it applies to changes in the licensee's own share register — which means an equity round has a regulatory fee attached to it that is not in anybody's term sheet by default.
What this does not tell you
Fees are one column of the cost model and not the largest. Paid-up and liquid capital under the Fifth Schedule, the nine operational policies required under regulation 6(2)(f), insurance under regulation 88 and the seven-year record-keeping obligations all cost more than the fees do. And the licensing deadline of 4 November 2026 under section 47 of the Virtual Asset Service Providers Act 2025 (Act No. 20 of 2025) sits above all of it, with no transitional provision and no savings clause anywhere in the 151 regulations.
One thing is genuinely open: the application window has not opened, and the application form has not been published. Anyone giving you a date for either is guessing. Budget the recurring cost now; the filing mechanics can only be finalised when the regulators publish them.
The checklist behind this article
Our Kenya VASP Licensing Readiness Checklist sets out the application and ongoing obligations under Legal Notice 134 line by line, each item cited to its regulation or schedule, each figure marked according to whether it is instrument text or reporting of it, and the open questions — the window, the form, the regulation 85(7) uplift — left marked as open. USD 79, with the updated edition free as the position develops.
If your position is straightforward — one activity category, one Kenyan entity, capital already in place — the checklist covers what you need. If it is not, for instance where you sit across the CBK and CMA split or expect a share transfer during the licensing period, our 48-hour gap check is at this link.