Kenya / Licence categories / Virtual Asset Wallet Provider

Virtual Asset Wallet Provider

Virtual Asset Wallet Provider: licensed by the Central Bank of Kenya (CBK). Minimum paid-up capital KSh 150 million, licence fee KSh 500,000.

Regulator

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

Regulator

Central Bank of Kenya (CBK), per the First Schedule of the Act. VASP Act 2025, First Schedule official

What it covers

Custodial wallet services (corporate and retail): services in which the private keys to the client's virtual assets are held and managed by a third party for proof of ownership and facilitation of transactions. VASP Act 2025, First Schedule official

Minimum paid-up capital

KSh 150,000,000, 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 30,000,000 or 100% of current liabilities for at least 30 days, 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Application fee KSh 100,000 (forfeited if the application is withdrawn, reg. 5(2)); licence fee KSh 500,000; annual renewal KSh 500,000 or 0.15% of gross turnover, whichever is higher. VASP Regulations 2026, First Schedule official

In practice

This is the licence for any business that holds clients' private keys: custodial wallets inside exchanges and payment apps, and stand-alone custodians serving corporate or retail clients. Non-custodial wallet software, where the user alone controls the keys, is not described in the First Schedule. Because exchanges usually hold client coins, a Kenyan exchange that keeps custody in-house will in practice need this Central Bank licence as well as its CMA exchange licence, and the higher wallet capital then sets its base requirement.

Category-specific duties

• segregate client assets from its own on separate on-chain addresses and separate internal ledger accounts (reg. 66(1)(a)–(c))
• reconcile on-chain holdings against internal records every month and give the records to the CBK by the 10th of the following month (reg. 66(1)(d))
• get explicit consent before holding client assets in omnibus accounts (reg. 66(1)(e))
• never lend, pledge or otherwise encumber client assets held for safekeeping (reg. 66(1)(g))
• send each client a statement of holdings at least every three months (reg. 66(1)(m))

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 CBK 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

Custody (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 CBK (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

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