How to Apply for a VASP Licence in Kenya
A step-by-step guide from classification through to post-licence obligations.
Read insight →The Virtual Asset Service Providers Act, 2025 and the 2026 Regulations now govern exchanges, wallets, payment processors, brokers, advisers, managers, tokenisation platforms and stablecoin issuers operating in or from Kenya. This hub organises our guidance by the question you actually need answered.
The transitional period for operators already providing virtual asset services when the Act commenced closes on 4 November 2026. See our transition deadline guide, or speak to us directly.
Request a transition readiness reviewA step-by-step guide from classification through to post-licence obligations.
Read insight →How Kenya's dual-regulator model splits jurisdiction by activity.
Read insight →The corporate, governance, financial and policy documents your file needs.
Read insight →How to budget for fees, capital and professional costs, using the final 2026 figures.
Read insight →What existing operators, new entrants and offshore platforms should each do.
Read insight →How the "in or from Kenya" jurisdictional test applies without a local presence.
Read insight →Market integrity, custody and systems obligations for trading venues.
Read insight →Custodial vs non-custodial models and where the regulatory line sits.
Read insight →Transaction flow mapping and CBK payment-system overlap.
Read insight →Issuer, platform and underlying-asset roles, and why title still matters.
Read insight →Disclosure, escrow and governance expectations for token launches.
Read insight →Reserve backing, custody and redemption requirements for issuers.
Read insight →Three distinct intermediary categories, compared side by side.
Read insight →Risk assessment, KYC/CDD, sanctions screening, monitoring and reporting.
Read insight →How directors, senior officers and beneficial owners are assessed.
Read insight →How segregation, records and incident planning protect customer assets.
Read insight →Technology governance, access control and incident response expectations.
Read insight →Incorporation, ownership and governance structuring for applicants.
Read insight →The CMA regulatory sandbox, SAFTs, SPVs and AML compliance.
Read insight →A practical pre-application audit you can print and work through with your team.
Read insight →The Virtual Asset Service Providers Act, 2025 (Act No. 20 of 2025) commenced on 4 November 2025, and the implementing Virtual Asset Service Providers Regulations, 2026 (Legal Notice No. 134 of 2026) were gazetted on 22 July 2026. Kenya has moved from an unregulated market to a defined licensing and supervisory regime administered jointly by the Central Bank of Kenya and the Capital Markets Authority. For businesses already operating, or planning to operate, in this space, the question is no longer whether regulation applies. It is which licence category fits, which regulator has jurisdiction, and what a compliant application requires.
Each guide above addresses a distinct, practical question, from initial classification through to category-specific requirements and ongoing compliance. For advice tailored to your specific business model, timeline and structure, our VASP Licensing & Regulatory Compliance service covers classification, application preparation and regulator engagement end to end.
The information on this website is general in nature, is not legal advice, and does not create an advocate-client relationship. Figures, fees, capital thresholds and procedural requirements under the Virtual Asset Service Providers Act, 2025 and the Virtual Asset Service Providers Regulations, 2026 should be confirmed against the current Gazette text and regulator guidance before action is taken. Please contact Njau & Associates Advocates for advice on your specific circumstances.