A virtual assets service provider briefing on operating under Kenya’s virtual asset regime
Published 10 August 2026 · The Virtual Asset Regulation Series
A licence under the Virtual Asset Service Providers Act, 2025 is not a document you obtain. It is an operating model you adopt.
This briefing sets out what that model requires — the parts of the framework that determine whether a business can realistically operate under it, rather than the headline features that have dominated the commentary.
It covers the people you must have in place and the standing each must hold, including the requirement that the chief executive officer be domiciled in Kenya and approved by the regulator. It covers the infrastructure: a physical office, a Kenyan bank account, locally placed insurance, and nine board-approved policies.
It explains where one licence is not enough — the separate Central Bank authorisation required for converting virtual assets to or from foreign currency, and the way capital stacks under regulation 85(6) when a business carries on more than one activity, worked through with figures.
It sets out the full reporting schedule, from monthly capital adequacy returns through to the daily reconciliation obligation on stablecoin issuers, and the three notification clocks that run in hours rather than weeks.
It addresses the framework’s reach beyond Kenya’s borders, and what that leaves open to an offshore platform with Kenyan users.
Finally, it identifies the application requirements with the longest lead times — the independent information systems audit, three years of audited financial statements, the fit and proper assessments — and sets them against the transitional deadline of 4 November 2026.
[ Download and Read the full briefing →]
Published by T.M.M & Partners Advocates. This briefing is general information and not legal advice.