Kenya / Licence categories / Virtual Asset Manager

Virtual Asset Manager

Virtual Asset Manager: licensed by the Capital Markets Authority (CMA). Minimum paid-up capital KSh 20 million, licence fee KSh 200,000.

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

Virtual asset management: managing portfolios that include virtual assets on a discretionary basis under client mandates. VASP Act 2025, First Schedule official

Minimum paid-up capital

KSh 20,000,000, 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 4,000,000 or 8% of total liabilities, whichever is higher. VASP Regulations 2026, Fifth Schedule official

Fees

Application fee KSh 50,000 (forfeited if the application is withdrawn, reg. 5(2)); licence fee KSh 200,000; annual renewal 0.05% of assets under management, minimum KSh 200,000 and maximum KSh 5,000,000. VASP Regulations 2026, First Schedule official

In practice

Managers run discretionary portfolios that include virtual assets, such as crypto funds or managed accounts. They may not keep client funds themselves: a custodian licensed in Kenya has to hold them. Renewal costs 0.05% of assets under management each year, with a floor of KSh 200,000 and a cap of KSh 5 million, so the fee grows with the book up to roughly KSh 10 billion of assets.

Category-specific duties

• appoint a custodian licensed in Kenya to safeguard client funds (reg. 87(2))
• keep investments in or through related companies to 10% of assets under management unless the regulator approves more (reg. 87(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
• Kenya Crypto Licence Costs: KSh 100 Million for an Exchange, KSh 300 Million for a Stablecoin

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