Kenya VASP Licensing & Compliance Resource Centre
The central hub for licence categories, CBK/CMA jurisdiction, costs, AML and the transition deadline.
Read insight →The Virtual Asset Service Providers Regulations, 2026 (Legal Notice No. 134 of 2026) fix exact fees in the First Schedule and exact capital and liquidity thresholds in the Fifth Schedule. The tables below reproduce those figures directly from the Gazette text.
Table A — Application, licence and renewal fees (First Schedule)
| Licence category | Application fee (KSh) | Licence fee (KSh) | Renewal fee (KSh) |
|---|---|---|---|
| Virtual Asset Wallet Provider | 100,000 | 500,000 | 500,000 or 0.15% of gross turnover, whichever is higher |
| Virtual Asset Exchange | 100,000 | 1,000,000 | 500,000 or 0.5% of gross revenue of the previous year, whichever is higher |
| Virtual Asset Payment Processor | 100,000 | 200,000 | Tiered by gross annual transaction value — see Table A1 |
| Virtual Asset Broker | 100,000 | 100,000 | 100,000 |
| Virtual Asset Investment Adviser | 10,000 | 50,000 | 50,000 |
| Virtual Asset Manager | 50,000 | 200,000 | 0.05% of assets under management, min. 200,000, max. 5,000,000 |
| Virtual Asset Offering Provider — Initial Coin Offering | 100,000 | 500,000 | 500,000 or 0.15% of gross turnover, whichever is higher |
| Virtual Asset Offering Provider — Virtual Asset Tokenisation | 100,000 | 500,000 | 500,000 or 0.15% of gross turnover, whichever is higher |
| Virtual Asset Offering Provider — Token Issuance Platform | 100,000 | 500,000 | 500,000 or 0.15% of gross turnover, whichever is higher |
| Virtual Asset Offering Provider — Stablecoin Issuance | 100,000 | 2,000,000 | 2,000,000 or 0.15% of gross turnover, whichever is higher |
Table A1 — Virtual Asset Payment Processor renewal fee, by transaction volume
| Gross transaction value per annum (KSh) | Renewal fee (KSh) |
|---|---|
| 0 – 1 billion | 20,000 |
| 1 billion + 1 – 10 billion | 100,000 |
| 10 billion + 1 – 50 billion | 500,000 |
| 50 billion + 1 – 100 billion | 1,000,000 |
| 100 billion + 1 – 500 billion | 5,000,000 |
| 500 billion + 1 – 1 trillion | 10,000,000 |
| Above 1 trillion | 15,000,000 |
Approval and other fees
| Fee | Amount |
|---|---|
| Approval of initial coin offering | 0.25% of the value of the successful offer, min. KSh 200,000, max. KSh 30,000,000 |
| Approval of virtual asset tokenisation | 0.25% of the value of the successful offer, min. KSh 200,000, max. KSh 30,000,000 |
| Approval of proposed acquisition, transfer or disposal of shares in a licensee | 0.25% of the transaction value or KSh 50,000, whichever is higher |
| Approval for assignment or transfer of a licence | The licence fee for the licence category |
Table B — Paid-up capital and liquid capital (Fifth Schedule)
| Licence category | Paid-up capital (KSh) | Liquid capital (KSh) |
|---|---|---|
| Virtual Asset Wallet Provider | 150,000,000 | 30,000,000 or 100% of current liabilities for at least 30 days, whichever is higher |
| Virtual Asset Exchange | 100,000,000 | 20,000,000 or 8% of total liabilities, whichever is higher |
| Virtual Asset Payment Processor | 10,000,000 | 100% of current liabilities for at least 30 days |
| Virtual Asset Broker | 10,000,000 | 2,000,000 or 8% of total liabilities, whichever is higher |
| Virtual Asset Investment Adviser | NIL | NIL |
| Virtual Asset Manager | 20,000,000 | 4,000,000 or 8% of total liabilities, whichever is higher |
| Virtual Asset Offering Provider — Initial Coin Offering | 20,000,000 | 4,000,000 or 8% of total liabilities, whichever is higher |
| Virtual Asset Offering Provider — Virtual Asset Tokenisation | 10,000,000 | 2,000,000 or 8% of total liabilities, whichever is higher |
| Virtual Asset Offering Provider — Token Issuance Platform | 20,000,000 | 4,000,000 or 8% of total liabilities, whichever is higher |
| Virtual Asset Offering Provider — Stablecoin Issuance | 300,000,000 | 60,000,000 or 100% of current liabilities for at least 30 days, whichever is higher |
"Paid-up capital" means issued and fully paid-up ordinary shares paid by shareholders of the company. Regulation 85(5) excludes unpaid, partly paid or contingent capital commitments, shareholder loans or advances, capital raised through borrowed funds, and revaluation reserves or internally generated intangible assets from counting as paid-up capital. "Liquid capital" means the amount by which a licensee's liquid assets exceed its liabilities, where a liquid asset is one that can be converted to cash without significant loss in value.
Regulation 85(6): holding more than one permissible activity
Where a licensee intends to, or has been authorised to, carry out more than one permissible activity, Regulation 85(6) requires it to hold the paid-up capital applicable to its highest-capital category, plus fifty percent of the paid-up capital for each additional activity undertaken. For example, a business licensed as both a Virtual Asset Wallet Provider (KSh 150,000,000) and a Virtual Asset Payment Processor (KSh 10,000,000) would need to hold KSh 150,000,000 (the higher category) plus 50% of KSh 10,000,000, a total of KSh 155,000,000. This stacking rule means multi-activity platforms should model their combined capital requirement before assuming a single category's threshold applies.
Core capital must also, under Regulation 85, be unencumbered, not pledged or charged, and not repayable or callable at a shareholder's initiative; the relevant regulatory authority may also require a licensee to increase its paid-up capital where its risk profile warrants it, and a licensee whose core capital falls, or is likely to fall, below the prescribed minimum must notify the regulator immediately and submit a remedial capital restoration plan.
Four distinct cost categories
Founders should keep four categories separate, since they are often conflated in early planning:
- Application fees payable when the licence application is lodged.
- Licensing fees payable on grant of the licence.
- Renewal fees payable periodically to maintain the licence.
- Paid-up and liquid capital that the licensee must hold and maintain, which is a prudential requirement rather than a fee, and varies by licence category.
Do not treat professional fees as regulator fees
Legal, accounting and consulting fees for preparing an application are a real and often substantial cost, but they are commercial fees paid to your advisers, not amounts paid to the CBK or CMA. Keep these separate in your budget so that investors and your own finance team can see the statutory cost of licensing distinct from the cost of getting there. The same applies to technology expenditure (systems, key management infrastructure), the independent information systems audit and penetration test the Regulations require as part of the application file, and ongoing audit and compliance costs once licensed, none of which are regulator fees, all of which are real budget items.
These figures may be varied over time
The figures above are reproduced from the First and Fifth Schedules to the Virtual Asset Service Providers Regulations, 2026 (Legal Notice No. 134 of 2026) as gazetted. Schedules to subsidiary legislation can be amended by further gazette notice, so confirm you are working from the current version of the Schedules before finalising a budget, particularly if some time has passed since your last review.
Capital planning is a governance question, not just a compliance one
Paid-up and liquid capital requirements are generally tiered by licence category and the scale of activity, reflecting the different risk profiles of, for example, a custodial wallet provider versus an advisory business. Founders raising capital should build the applicable capital requirement into their cap table and use-of-funds planning from the outset, since it is a precondition of licensing rather than a target to be met after the business is already operating.
Budgeting checklist
- Confirm the current application, licensing and renewal fees for your specific licence category against the Gazette text.
- Confirm the paid-up and liquid capital thresholds applicable to your category, and how liquid capital must be maintained on an ongoing basis.
- Separate statutory fees from professional advisory costs in your budget and cap table planning.
- Plan capital raising with enough lead time to have funds in place before, not during, the application process.
Need help budgeting for your VASP application?
We confirm the current fee and capital requirements for your specific licence category and help structure your capital raise around them.
Request a Costs & Capital ReviewKey legal & regulatory sources
- Kenya Law — Virtual Asset Service Providers Act, 2025 (Act No. 20 of 2025)
- Kenya Law — Virtual Asset Service Providers Regulations, 2026 (Legal Notice No. 134 of 2026)
- Central Bank of Kenya and Capital Markets Authority public guidance on VASP licensing
Frequently asked questions
Are Kenya's VASP capital requirements the same for every licence category?
No. The Fifth Schedule sets a different paid-up and liquid capital figure for each licence category, ranging from nil for a Virtual Asset Investment Adviser to KSh 300,000,000 in paid-up capital for a Stablecoin Issuance provider, reflecting the different risk each activity poses.
What capital must a licensee hold if it carries on more than one licensed activity?
Regulation 85(6) requires the licensee to hold the paid-up capital of its highest-capital category, plus fifty percent of the paid-up capital for each additional activity undertaken, rather than simply adding the full capital figure for each activity together.
Should I include legal and advisory fees in my licensing cost estimate?
Yes, but track them separately from statutory application, licensing and renewal fees paid to the regulator, since they serve different purposes in your budget and are not government charges.
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Read insight →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.