Kenya / Licence categories / Virtual Asset Investment Advisor

Virtual Asset Investment Advisor

Virtual Asset Investment Advisor: licensed by the Capital Markets Authority (CMA). Minimum paid-up capital nil, licence fee KSh 50,000.

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

Investment advisory services: investment advice on virtual assets, initial virtual asset offerings and non-fungible tokens for individual or institutional clients. VASP Act 2025, First Schedule official

Minimum paid-up capital

nil, 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

Nil. VASP Regulations 2026, Fifth Schedule official

Fees

Application fee KSh 10,000 (forfeited if the application is withdrawn, reg. 5(2)); licence fee KSh 50,000; annual renewal KSh 50,000. VASP Regulations 2026, First Schedule official

In practice

Advisers give investment advice on virtual assets, token offerings and NFTs for clients. It is the cheapest licence: no paid-up or liquid capital, a KSh 10,000 application fee and a KSh 50,000 licence fee, but a professional indemnity policy of at least KSh 1 million is compulsory. Paid signal groups and research subscriptions that recommend specific trades to Kenyan clients should check whether their service is advice in this sense.

Category-specific duties

• hold professional indemnity cover of at least KSh 1,000,000 (reg. 88(6))
• only give advice that is suitable for the client on the facts the client disclosed (reg. 25(3))

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

Broking, advice and management (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
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