Kenya VASP Licensing & Compliance Resource Centre
The central hub for licence categories, CBK/CMA jurisdiction, costs, AML and the transition deadline.
Read insight →A business that moves value between fiat currency and virtual assets, or processes virtual asset payments on behalf of merchants, sits at the intersection of payments law and the new VASP framework.
Virtual asset payment processing sits among the activities generally associated with Central Bank of Kenya oversight, reflecting its function as a payment rail rather than an investment or trading activity. Businesses in this category should also expect their analysis to touch Kenya's existing payment systems law, since a crypto-fiat gateway is, functionally, a payment service with a virtual asset leg.
The starting point for any payment processor is a precise map of how value actually moves: where fiat currency enters, where it converts to or from a virtual asset, who holds funds at each stage, and where settlement finally occurs. This map, not the marketing description of the product, is what determines the regulatory analysis.
A payment processor that also custodies virtual assets between conversion legs, or that operates its own conversion engine resembling an exchange, may need to consider its position under more than one activity category. This is a common structuring point for fintechs adding a crypto rail to an existing payments business, and it should be assessed activity by activity rather than assumed to be covered by a single payment licence.
A business already licensed or authorised under Kenya's existing payment systems framework should not assume that authorisation extends automatically to a new virtual asset function. The VASP Act creates a distinct licensing requirement for virtual asset activities, which should be assessed and, where required, applied for separately alongside your existing payment authorisation.
We map your transaction flow against the VASP framework and your existing payment authorisations.
Discuss Your Payment Processing ModelGenerally, a merchant simply accepting virtual assets as payment for its own goods or services is not itself providing a virtual asset service. The payment processor facilitating the conversion and settlement on the merchant's behalf is the party whose activity is more likely to require licensing.
Not automatically. A virtual asset payment function is a distinct regulated activity under the VASP Act and should be assessed, and licensed if required, on its own terms alongside any existing payment authorisation.
Cross-border and foreign-currency elements of a payment flow should be checked against Central Bank of Kenya foreign exchange rules in addition to the VASP-specific licensing analysis, since the two frameworks apply concurrently.
The central hub for licence categories, CBK/CMA jurisdiction, costs, AML and the transition deadline.
Read insight →Licensing requirements for platforms that facilitate trading in virtual assets.
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.