Kenya / Licence categories / Virtual Asset Exchange

Virtual Asset Exchange

Virtual Asset Exchange: licensed by the Capital Markets Authority (CMA). Minimum paid-up capital KSh 100 million, licence fee KSh 1,000,000.

Regulator

Licensed by the CMA · checked 22 Oct 2026
Kenya has two licensing authorities; the First Schedule of the Act assigns each activity to one of them.

Regulator

Capital Markets Authority (CMA), per the First Schedule of the Act. VASP Act 2025, First Schedule official

What it covers

Transfer and conversion of virtual assets; trading, clearing and settlement platforms: a digital platform facilitating virtual asset transfers and exchanges, between virtual assets or between virtual assets and fiat currency, and platforms for the sale, trading or exchange of virtual assets. VASP Act 2025, First Schedule official

Minimum paid-up capital

KSh 100,000,000, held at licensing and at all times after; shareholder loans, borrowed money and revaluation reserves do not count (reg. 85(3) and (5)). VASP Regulations 2026, Fifth Schedule official

Liquid capital

KSh 20,000,000 or 8% of total liabilities, whichever is higher. VASP Regulations 2026, Fifth Schedule official

Fees

Application fee KSh 100,000 (forfeited if the application is withdrawn, reg. 5(2)); licence fee KSh 1,000,000; annual renewal KSh 500,000 or 0.5% of the previous year's gross revenue, whichever is higher. VASP Regulations 2026, First Schedule official

In practice

The exchange category covers both order-book platforms that match buyers and sellers and conversion services that swap one virtual asset for another or for shillings. The Act's definition of a trading platform includes one that holds client assets or buys from sellers to sell on to buyers, which takes in brokerage-style 'instant buy' apps. Peer-to-peer marketplaces that hold assets in escrow while users trade may fall within the same wording. Exchanges, like token issuance platforms, must report every listing and delisting decision to the CMA each month.

Category-specific duties

• have business rules approved by the CMA, published and legally enforceable by clients, covering listing and delisting, order matching, settlement, fees, custody and market abuse (reg. 20)
• carry out and record due diligence on every virtual asset before admitting it to trading, including smart-contract audits and AML/CFT/CPF checks (reg. 33)
• not list any stablecoin unless the Central Bank of Kenya has approved it and it is issued by a licensed stablecoin issuer (reg. 60(6))
• report new listings and delistings to the CMA monthly, by the 10th of the following month (reg. 60(5))
• give client orders priority over its own proprietary orders (reg. 35)

VASP Regulations 2026, Parts III to IX official

Deadline for existing operators

Anyone already providing virtual asset services must comply with the Act within one year of its commencement on 4 November 2025 (s. 47), which by our calculation is 4 November 2026. The Regulations contain no further transition period. VASP Act 2025, s. 47 official

Register

The CMA must publish a register of the licences it issues (s. 17) and gazette each grant within 30 days (s. 10(7)). We found no published VASP register; the CMA licensee directory, checked 22 Oct 2026, has no virtual-asset category. CMA licensee directory official

Group

Trading venue (Group)

Public statement

Not applicable: this page describes a licence category, not a firm.

Key Dates for This Category

• 4 Nov 2025The VASP Act 2025 commences; the activity needs a licence from the CMA (s. 8(2)). — new.kenyalaw.org official
• 22 Jul 2026The VASP Regulations 2026 (Legal Notice 134) set capital, fees and conduct rules for the category and open licensing. — cma.or.ke official
• 4 Nov 2026End of the one-year window for existing providers to comply (s. 47; date calculated by VASP Tracker). — new.kenyalaw.org official

Read More

• Kenya's Crypto Licensing Deadline Is 4 November 2026, and No Licence Register Has Been Published
• Kenya Crypto Licence Costs: KSh 100 Million for an Exchange, KSh 300 Million for a Stablecoin

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