Methodology · Kenya

How the Kenya tracker is built, and what it can and cannot show while no VASP register exists.

Sources

• Virtual Asset Service Providers Act, 2025 (Act No. 20 of 2025), Kenya Law: commencement, licence categories, offences, transition (s. 47).
• Virtual Asset Service Providers Regulations, 2026 (Legal Notice 134), Gazette supplement as published by the CMA; also on Kenya Law. Capital, fees and conduct rules are copied from the First and Fifth Schedules.
• Draft Regulations of 17 March 2026 (CMA), used only for the draft-versus-final capital comparison.
• CBK and CMA public notice, 18 November 2025; National Treasury public notice on the draft.
• CMA licensee directory, read on every build (19 categories, 0 for virtual assets, 22 Oct 2026).
• FATF, jurisdictions under increased monitoring, 19 June 2026.

Source Hierarchy

1. official Kenya Law, Kenya Gazette (via the CMA), CBK, CMA, National Treasury, FATF.
2. company none used.
3. press · secondary none used.

Why the Table Lists Licence Categories, Not Firms

Every other country hub lists firms from an official register. Kenya's Act requires the CBK and CMA to publish registers (s. 17), but none has been published. Until one is, the table lists the ten licence categories so that a reader can look up the regulator, capital and fees for a business model. Firms will be added from the registers or Gazette notices only.

Calculated Dates

• 4 November 2026: one year after commencement (s. 47).
• 5 October 2026: thirty days before that date (reg. 6(4)).
• Day counts are calendar days.

Limits

• Kenya Law blocks automated reads; the Act's text was checked by hand and the Regulations are read from the CMA's PDF.
• The Kenya Gazette itself is not searched for licence grants; we rely on the regulators' registers and notices.
• Amounts are in Kenya shillings; we do not convert them.

Corrections

Write to press@vasptracker.com with the page and the source. Published corrections: none.