Kenya Crypto Licence Costs: KSh 100 Million for an Exchange, KSh 300 Million for a Stablecoin

The short version: Kenya's minimum paid-up capital for a crypto licence runs from nil for an investment adviser to KSh 300 million for a stablecoin issuer; an exchange needs KSh 100 million and a custodial wallet provider KSh 150 million (Regulations, Fifth Schedule). The final rules cut the capital floor in 9 of 10 categories compared with the March 2026 draft (draft Regulations).

All Ten Categories

Paid-up capital and liquid capital: Fifth Schedule. Fees: First Schedule. Draft: Fifth Schedule of the draft published on 17 March 2026.

From Draft to Final

Added across all ten categories, the minimum paid-up capital fell from KSh 1,512.5 million in the draft to KSh 640 million in the gazetted text. The largest cuts in relative terms were for token offerings: tokenisation from KSh 200 million to KSh 10 million, and initial coin offerings and token issuance platforms from KSh 200 million to KSh 20 million each. Exchanges went from KSh 150 million to KSh 100 million, stablecoin issuers from KSh 500 million to KSh 300 million, payment processors from KSh 50 million to KSh 10 million and brokers from KSh 30 million to KSh 10 million. The investment adviser requirement of KSh 2.5 million was dropped. Only the custodial wallet provider figure was unchanged at KSh 150 million. The draft had also set an exchange's liquid capital as half of its estimated operating costs for the next twelve months; the final text uses KSh 20 million or 8% of total liabilities instead.

What Counts as Capital

The capital must be held at licensing and at all times after it, as core capital of at least the scheduled amount (Regulations, reg. 85(3)). Shares count as paid up only if paid in cash or in other consideration the regulator accepts. Unpaid commitments, shareholder loans, money raised through borrowing and revaluation reserves do not count, and the capital may not be pledged or be repayable at a shareholder's option (Regulations, reg. 85(4), (5), (8)). Dressing up the capital position to pass the test is a separate criminal offence (Regulations, reg. 86). If capital falls, or is likely to fall, below the minimum, the licensee must tell the regulator at once and file a restoration plan (Regulations, reg. 85(13)).

Holding More Than One Licence

A firm with several activities holds the full capital of its most expensive category plus half of the capital for each additional one (Regulations, reg. 85(6)). An exchange that also offers custodial wallets therefore needs KSh 150 million plus half of KSh 100 million, or KSh 200 million, not the full sum of both. The regulator may also demand more capital for a riskier business (Regulations, reg. 85(7)).

Fees

Application fees are KSh 100,000 for most categories (KSh 50,000 for a manager, KSh 10,000 for an adviser) and are lost if the application is withdrawn (Regulations, reg. 5(2), First Schedule). Licence fees range from KSh 50,000 for an adviser to KSh 1 million for an exchange and KSh 2 million for a stablecoin issuer. Renewal is annual and scales with the business: an exchange pays KSh 500,000 or 0.5% of the previous year's gross revenue, whichever is higher; a payment processor pays between KSh 20,000 and KSh 15 million depending on its yearly transaction value (Regulations, First Schedule). Exchange fees were also cut from the draft, which had set a KSh 2 million licence fee and a renewal of 2% of the previous year's gross income or KSh 2 million, whichever was higher (draft, First Schedule).

Beyond Capital

Every licensee needs insurance for clients' virtual assets with an insurer licensed in Kenya or one the regulator approves with the Insurance Regulatory Authority, including cover for cyber risks, theft and loss of keys (Regulations, reg. 88). The board needs at least three members, a third of them independent, and the chair may not be the chief executive (Regulations, reg. 42); the finance and internal-audit heads must be members of ICPAK or an equivalent body it recognises (Regulations, reg. 45).