Kenya: Virtual Asset Service Providers Act 2025 (Act No. 20 of 2025) including licensing requirement enters into force for existing providers

On 4 November 2026, the one-year transitional period under section 48 of the Virtual Asset Service Providers Act, 2025 (Act No. 20 of 2025) expires. From this date, all persons providing virtual asset services in or from Kenya must hold a valid licence granted by the Capital Markets Authority or the Central Bank of Kenya, as applicable by activity type under the First Schedule to the Act. Eligibility is restricted to local companies incorporated under the Companies Act (Cap. 486) and foreign companies issued with a certificate of compliance under the Companies Act (Cap. 486). Natural persons are prohibited from carrying on virtual asset services in or from Kenya. Permissible activities subject to the licensing requirement include custodial wallet services, virtual asset exchange, payment processing, brokerage, investment advisory, asset management, initial coin offerings, tokenisation, and stablecoin issuance. A person who contravenes the licensing requirement commits a criminal offence and is liable, upon conviction, to a fine not exceeding KES 10 million or imprisonment for a term not exceeding 5 years, or both, in the case of an individual, and to a fine not exceeding KES 25 million in the case of a company.