Kenya VASP licence deadline: crypto firms must be licensed by 4 November 2026

Crypto firms serving customers in Kenya have until 4 November 2026, as law firms count it, to hold a licence under the Virtual Asset Service Providers Act, 2025. That is when the one-year transition in the law runs out. Exchanges, brokers and token platforms answer to the Capital Markets Authority (CMA). Custodial wallet providers, payment processors and stablecoin issuers answer to the Central Bank of Kenya (CBK). Offshore platforms that target Kenyan users are covered too.

As of 23 October 2026, neither regulator had announced a licence, an application window or an extension. The detailed rules have been in force since 22 July 2026.

Where the 4 November 2026 deadline comes from

No official text prints the date. It is a calculation. The Act (No. 20 of 2025) was assented to on 15 October 2025 and published in the Kenya Gazette on 21 October. According to the Act’s page on Kenya Law, it commenced on 4 November 2025, and a joint public notice from the CBK and the CMA dated 18 November 2025 gives the same date.

Section 47, headed “Transitional and saving provisions”, is one sentence long. It says that on commencement, anyone providing virtual asset services shall, “within one year of the commencement, comply with the provisions of this Act”. One year after 4 November 2025 lands on 4 November 2026. Some commentaries cite section 48 for this rule; in the Kenya Law text, section 48 covers consequential amendments to other laws.

Because the Act counts in years rather than naming a day, the exact last day is a matter of reading. Digital Policy Alert and several Kenyan law firms use 4 November 2026, and so do we. Neither the CBK nor the CMA has published a date of its own.

Who needs a Kenya VASP licence, and from which regulator

Section 8(2) of the Act says a person shall not carry on, or purport to carry on, a virtual asset service business “in or from Kenya” unless licensed by the relevant regulator. Under section 8(1), only a company limited by shares, or a foreign company limited by shares, registered under Kenya’s Companies Act can apply.

The Virtual Asset Service Providers Regulations, 2026 (Legal Notice 134 of 2026) stretch that reach. Regulation 4(2) treats a firm as operating in or from Kenya if it actively solicits or targets local consumers, or derives an economic benefit or income from Kenya, whether or not it has an office in the country. A global exchange with Kenyan customers falls inside that definition on its own terms.

The First Schedule of the Act gives each activity to one regulator:

Two rules in the Regulations reach beyond the licence itself. Regulation 14 says anyone who wants to run a business converting virtual assets to or from foreign currency must first obtain CBK authorisation. And under the listing rules, an exchange may not list a stablecoin unless the CBK has approved it and a licensed stablecoin issuer issues it.

What the 2026 Regulations require: capital, fees, timelines

The National Treasury put draft regulations out for comment in March 2026, with comments due by 10 April. The final text was gazetted and took effect on 22 July 2026. In their November 2025 public notice, the CBK and the CMA had said licensing would start only once these regulations were issued, and that they had licensed no provider under the Act.

An applicant files the form in the Second Schedule with a business plan, a set of policies (AML, cybersecurity, consumer protection, complaints and others), the personal details of its directors, senior officers, significant shareholders and beneficial owners, a fit-and-proper assessment form, proof of source of funds, three years of audited accounts or, for a new company, opening statements verified by an auditor, and an independent information systems audit. Under regulation 6(4), the regulator decides within thirty days of receiving the complete file and finishing its due diligence.

The Fifth Schedule sets minimum paid-up capital and the First Schedule sets fees. The main figures:

A firm doing several activities holds the capital for the most demanding one plus 50% of the capital of each extra activity (regulation 85(6)). Liquid capital comes on top: for an exchange, KES 20 million or 8% of total liabilities, whichever is higher.

Once licensed, a firm has 12 months to start business (regulation 8). It cannot ask to transfer or assign the licence until it has held it for 36 months from the start of business (regulation 13). On 27 July 2026, Business Daily read that clause as aimed at people who seek permits only to sell them on.

What the Act says about operating without a licence

Breaching section 8 is an offence, with penalties set in section 40(3). On conviction, an individual faces a fine of up to KES 10 million, up to five years in prison, or both. A company faces a fine of up to KES 25 million. Section 39 separately lets the regulator take administrative action, from written warnings to directions and restrictions, against any person who violates the Act.

Section 41 makes directors, partners and senior officers personally liable when they knowingly authorised, permitted or aided an offence committed by a licensee. The section is worded around licensees, and the Act does not say in so many words how it applies to a firm that never held a licence.

Nor does the Act spell out what changes on the day the one-year window closes. We found no grandfathering clause in the Regulations, and commentators disagree on whether unlicensed activity was already unlawful during the transition year. Neither regulator has published an enforcement plan.

Binance, Yellow Card, VALR, Luno and Kotani Pay: stated plans

No company has publicly confirmed filing an application. What exists are intentions, collected by TechCabal on 7 August 2026. Binance said it intends to apply after taking part in the consultation, without naming licence categories. Larry Cooke, head of legal at Binance Africa, described the licensing process as a two-year journey for the company. For background on the exchange, see our Binance review.

Yellow Card plans to apply for exchange and payment-processing licences and expects to file within three to four weeks of the regulators formally announcing the process, according to Edline Murungi, its group head of policy. VALR’s Kenya country manager, Peter Mwangi, said it expects to apply for exchange, custody and wallet, and payment-processing activities.

Kotani Pay’s chief operating officer, Samuel Kariuki, told TechCabal: “Yes, we will apply for a VASP licence.” He added that it was too early to give a timeline. Luno was still reviewing which categories fit its business-to-business lines. TechCabal also cited Chainalysis figures putting Kenya’s crypto inflows at about $19 billion between July 2024 and June 2025, against about $7 billion a year earlier.

What changes for Kenyan crypto users

Kenya is a large market for stablecoins and mobile-money on-ramps. The listing rule matters here: only CBK-approved stablecoins from a licensed issuer may be listed on an exchange, so the tokens described in our guide to stablecoins would each need that approval to stay on a licensed Kenyan exchange. As of 23 October 2026 no stablecoin had been publicly approved.

The Act also amends the Proceeds of Crime and Anti-Money Laundering Act so that virtual asset service providers become “reporting institutions”, the same status banks hold. That brings customer due diligence and suspicious-transaction reporting, which users meet as KYC checks.

No platform has announced service changes for Kenya, and neither regulator has published a register of licensed providers. The notice of November 2025 lists contact addresses for questions: [email protected] at the CBK and [email protected] at the CMA. Our exchange checklist covers licensing in general terms.

How Kenya’s approach compares with MiCA in Europe

European readers will recognise the structure. Under MiCA, crypto-asset service providers need authorisation from a national competent authority, which they can then passport across the EU, and national transition periods ended by 1 July 2026. Our MiCA explainer covers the details.

Kenya splits supervision by activity instead. The central bank takes payments, custody and stablecoins; the securities regulator takes trading and investment services. A firm active on both sides deals with both. There is no passport: the licence covers Kenya only.

Open questions before 4 November

On 23 October 2026 nobody outside the regulators could say whether any application had been filed or any licence granted. It was also unclear whether the CBK or the CMA would open an online portal, publish guidance or extend the transition, and how enforcement would begin. That day, the newest virtual asset items we found on the two regulators’ sites were old ones: the CBK’s call for comments on the draft regulations and the CMA’s notice on the commencement of the Act. Kenyan and regional coverage in October, including a 12 October piece in The Africans Time, repeated the 4 November date but quoted no regulator.

One call for more time has been made in public. On 12 October, TechTrendsKE reported that Africa Digital Assets, a Nairobi digital assets firm, wanted the government to push the licensing transition back to August 2027. Its founder, Fredrick Onyango Ogola, argued that Kenya lacks enough local use cases to guide the rules. By 23 October 2026 no regulator response had been reported, and the Act on Kenya Law still showed a single, unamended version.

A notice from either regulator, or a first list of licensees, will show how the deadline is applied.