Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the CBK authorisation, including banking and payment rails.
Get a payment license in Kenya.
Kenya runs payments on the National Payment System Act of 2011 and the National Payment System Regulations of 2014. The Central Bank of Kenya authorises an electronic retail payment service provider on KES 5 million of core capital, an e-money issuer on KES 20 million and an issuer of a designated payment instrument on KES 50 million, with a small e-money issuer regime at KES 1 million. Customer money goes into a Trust Fund placed in licensed banks or Government of Kenya securities, and e-money is capped at KES 70,000 a transaction with KES 1 million loaded a month. The Act sets no deadline for the central bank to decide. Forty-three payment service providers held authorisation at 17 June 2026, nine of them mobile-money issuers.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Kenya in brief
Four capital tiers, a Trust Fund, and no clock on the regulator.
The National Payment System Act, No. 39 of 2011, and the National Payment System Regulations of 2014 carry the whole regime, both in English and neither amended since. Regulation 11 and Table A of the First Schedule set core capital, held at the time of authorisation and at all times after it: KES 5,000,000 for an electronic retail payment service provider, KES 20,000,000 for an e-money issuer, KES 50,000,000 for an issuer of a designated payment instrument, and KES 1,000,000 for a small e-money issuer. That last regime, in Regulations 46 and 47, is for an issuer whose e-money accounts carry an individual transaction limit no higher than KES 20,000 and whose total e-money liabilities stay under KES 100 million. Regulation 25 is the safeguarding rule: the provider establishes a Trust, holds all monies received in a Trust Fund whose balance is never less than what is owed to customers, and places those funds in commercial banks licensed under the Banking Act or in Government of Kenya securities. Regulation 43 caps a single e-money transaction at KES 70,000 and the monthly load at KES 1,000,000, with the central bank free to approve higher limits.
Three points shape the timetable. The Act and the Regulations set no deadline for the central bank to grant or refuse; what they print is a 30-day window for the bank to request further information under Regulation 5(3) and a seven-day rule for issuing the certificate once the authorisation fees are paid, under Regulation 5(7). The Fourth Schedule placement limits for the Trust Fund are cross-referenced by Regulation 25(4) but do not appear in the published PDF, so we obtain them for your case. Regulation 44 requires redemption at par and bars the issuer from earning interest or any other return from the holder, and Regulation 45 rules out lending. The market is the reason people come: 43 authorised payment service providers at 17 June 2026, nine of them mobile-money issuers, with M-PESA at the centre and PesaLink carrying interbank instant transfers. Settlement is on KEPSS. Corporate tax is 30% for a resident company and 37.5% for a branch, VAT 16%. We run the file from Dubai and plan on eight to fourteen months.
The NPS Act 2011 and the 2014 Regulations set core capital in Regulation 11: KES 5,000,000 for a retail payment service provider, KES 20,000,000 for an e-money issuer, KES 50,000,000 for an instrument issuer and KES 1,000,000 for a small e-money issuer. Regulation 25 puts customer money in a Trust Fund held in licensed banks or government securities.
Regulation 43 caps e-money at KES 70,000 a transaction and KES 1,000,000 loaded a month. The Act gives the regulator no decision deadline, only a 30-day information request and a seven-day certificate rule. Forty-three PSPs at 17 June 2026, nine of them mobile-money issuers. We run it from Dubai.
The routes
Payment service provider, e-money issuer - or the small e-money regime.
One authorisation regime with four capital figures behind it. The services you sell decide the tier, and the tier decides the Trust Fund you have to run. We fix the route first, then build once.
Retail PSP, e-money issuer or instrument issuer - with a small e-money route beneath.
01 - PAYMENT SERVICE PROVIDER
Electronic retail payment service provider
Authorisation by the Central Bank of Kenya under the 2014 Regulations for electronic retail payment services, on KES 5,000,000 of core capital under Regulation 11, with the Trust Fund of Regulation 25 and the agent and cash-merchant rules of Regulations 14 to 20.
Authorisation by the Central Bank of Kenya under the 2014 Regulations for electronic retail payment services, on KES 5,000,000 of core capital under Regulation 11, with the Trust Fund of Regulation 25 and the agent and cash-merchant rules of Regulations 14 to 20.
- ✓Electronic retail payment services for Kenyan customers
- ✓Core capital KES 5,000,000 (Regulation 11, First Schedule)
- ✓Capital held at authorisation and at all times after it
- ✓Trust Fund in licensed banks or government securities
- ✓Agents and cash merchants under Regulations 14 to 20
- ✓Certificate within seven days of the authorisation fees
02 - E-MONEY ISSUER
E-money - KES 20,000,000E-money issuer and payment instruments
Authorisation to issue e-money on KES 20,000,000 of core capital, or KES 50,000,000 to issue a designated payment instrument. Below both sits the small e-money issuer at KES 1,000,000, for accounts with a transaction limit no higher than KES 20,000.
E-money issuer: KES 20,000,000 core capital; instrument issuer KES 50,000,000; small e-money issuer KES 1,000,000 with a KES 20,000 transaction limit.
- ✓E-money issuance on core capital of KES 20,000,000
- ✓Designated payment instrument issuer at KES 50,000,000
- ✓Small e-money issuer at KES 1,000,000 (Regulations 46 and 47)
- ✓KES 70,000 a transaction · KES 1,000,000 loaded a month
- ✓Redemption at par · no interest earned from the holder
- ✓No lending or investment beyond what the Regulations require
Costs and timelines are confirmed for your case before any work begins. The authorisation fees, the trust deed, the Trust Fund placements and substance are itemised in your quote.
Why Kenya
The market that taught mobile money to the rest of the continent.
Kenya has 47,564,296 people counted at the last census, nine licensed mobile-money issuers and a payments culture built around them. The licence is the way into that market, on capital figures a European founder will find modest.
✓
Four capital tiers, all printed
KES 5 million, 20 million, 50 million and 1 million, in Regulation 11 and Table A of the First Schedule. No discretionary figure and no negotiation.KES 1M to 50M, printed in the Regulations.
✓
A small e-money door
Regulations 46 and 47 open a KES 1,000,000 route for an issuer whose accounts cap transactions at KES 20,000 and whose e-money liabilities stay under KES 100 million.KES 1,000,000 with capped accounts.
✓
The Trust Fund rule is plain
Regulation 25: a Trust, a Trust Fund never below what customers are owed, and placements limited to licensed commercial banks or Government of Kenya securities.Banks or government securities only.
✓
M-PESA and PesaLink
Nine mobile-money issuers hold authorisation, and interbank instant transfers run through PesaLink, itself operated by an authorised provider. Settlement is on KEPSS.Nine mobile-money issuers authorised.
✓
English law, English regulator
The Act, the Regulations, the authorisation procedures and the checklist are English originals. Nothing in the file is translated, and nothing is lost in it.Act, rules and checklist in English.
✓
A published procedure
The central bank publishes both the authorisation procedure for payment service providers and the checklist that goes with it, so the file is built against the regulator's own list.The regulator prints its own checklist.
How it compares
How Kenya differs from the other East and West African routes.
Kenya has the deepest mobile-money market of the four and the lowest capital for a plain payment service provider. What it does not have is a decision deadline. The honest comparison is below.
Kenya vs other jurisdictions
| Feature |  Kenya | Other jurisdictions |
|---|---|---|
| Capital | KES 5M / 20M / 50M · small e-money 1M | GHS 0.8M-20M Ghana · FRW 30M-300M Rwanda |
| Decision clock | None in the Act or the Regulations | 90 days Ghana · none printed in Rwanda |
| Client funds | Trust Fund in banks or government securities | 100% of the float in liquid assets in Ghana |
| Corporate tax | 30% resident · 37.5% branch | 25% Ghana · 28% Rwanda · 30% Nigeria |
Capital
KenyaKES 5M / 20M / 50M · small e-money 1M
Other jurisdictionsGHS 0.8M-20M Ghana · FRW 30M-300M Rwanda
Decision clock
KenyaNone in the Act or the Regulations
Other jurisdictions90 days Ghana · none printed in Rwanda
Client funds
KenyaTrust Fund in banks or government securities
Other jurisdictions100% of the float in liquid assets in Ghana
Corporate tax
Kenya30% resident · 37.5% branch
Other jurisdictions25% Ghana · 28% Rwanda · 30% Nigeria
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Kenya | PSP · e-money issuer (CBK) | 30% · VAT 16% | KES 5M / 20M / 50M · no clock |
 Rwanda | Categories I-IV (BNR) | 28% · VAT 18% | FRW 30M-300M · fee FRW 1M-5M |
 Ghana | DEMI · PSP tiers (Bank of Ghana) | 25% · VAT 15% + levies | GHS 0.8M-20M · 90 days |
 Nigeria | MMO · PSSP (CBN) | 30% large companies | NGN 2bn MMO · NGN 100M PSSP |
KenyaLicense typePSP · e-money issuer (CBK)
Taxation30% · VAT 16%
RequirementsKES 5M / 20M / 50M · no clock
RwandaLicense typeCategories I-IV (BNR)
Taxation28% · VAT 18%
RequirementsFRW 30M-300M · fee FRW 1M-5M
GhanaLicense typeDEMI · PSP tiers (Bank of Ghana)
Taxation25% · VAT 15% + levies
RequirementsGHS 0.8M-20M · 90 days
NigeriaLicense typeMMO · PSSP (CBN)
Taxation30% large companies
RequirementsNGN 2bn MMO · NGN 100M PSSP
Before you apply
Requirements for the CBK authorisation.Requirements for the authorisation.
The Regulations set the capital, the trust and the product limits; the central bank's published procedure and checklist set the documents. The list below is what a passing file contains.
01
A company incorporated in Kenya, with a foreign-owned applicant supplying a no-objection from its home regulator under Regulation 8 and the Second Schedule.
02
Core capital at the Regulation 11 tier - KES 5,000,000, 20,000,000, 50,000,000 or 1,000,000 - held at the time of authorisation and at all times afterwards.
03
Fit-and-proper assessment of significant shareholders, trustees, directors and senior managers, on the forms the Second Schedule prescribes.
04
A trust deed and a Trust Fund under Regulation 25, with the balance never below what is owed to customers and the trustee's role separated from the operating business.
05
Placement of the Trust Fund in commercial banks licensed under the Banking Act or in Government of Kenya securities, within the Fourth Schedule limits that Regulation 25(4) cross-references and the published text omits.
06
An e-money product built to Regulation 43 - KES 70,000 a transaction and KES 1,000,000 loaded a month - or to the KES 20,000 limit if you apply as a small e-money issuer.
07
Redemption at par under Regulation 44, no interest or other return earned from the holder, and no lending or investment activity beyond what Regulation 45 allows.
08
Outsourcing arrangements within Regulation 23 and record-keeping to Regulation 29, both described in the application rather than promised for later.
09
An AML and counter-terrorist-financing policy, plus cybersecurity arrangements to the central bank's guidelines for payment service providers.
10
Agent and cash-merchant contracts under Regulations 14 to 20 for any distribution network, with the liability of the provider for its agents spelled out.
01
Company incorporated in Kenya; foreign owner supplies a no-objection.
02
Core capital KES 5M / 20M / 50M / 1M, held at all times.
03
Fit and proper: shareholders, trustees, directors, managers.
04
Trust deed and Trust Fund never below what is owed.
05
Placements in licensed banks or government securities.
06
E-money built to KES 70,000 and KES 1,000,000 limits.
07
Redemption at par; no interest from the holder; no lending.
08
Outsourcing within Regulation 23; records to Regulation 29.
09
AML policy and cybersecurity to CBK guidelines.
10
Agent and cash-merchant contracts (Regulations 14 to 20).
Reflects the National Payment System Act No. 39 of 2011, the National Payment System Regulations 2014 and the Central Bank of Kenya's published authorisation procedure and checklist, as of 2026.NPS Act No. 39 of 2011; NPS Regulations 2014; CBK authorisation procedure and checklist, as of 2026.
How it works
From first call to the CBK register.
01
Route and strategy
Retail PSP, e-money issuer, instrument issuer or the small e-money regime; capital tier and budget fixed in writing.Tier and services fixed in writing.
02
Company and capital
Kenyan company incorporated, core capital raised to the Regulation 11 figure, shareholders and managers documented.Incorporated, capital raised, owners documented.
03
Trust and application
Trust deed, trustee and placements settled; the application, business plan, AML and cybersecurity file built to the central bank's checklist.Deed, trustee, checklist file built.
04
CBK review
The 30-day information requests answered as they come. There is no statutory deadline, so plan on eight to fourteen months end to end.No deadline; 8-14 months realistic.
05
Certificate and launch
Authorisation fees paid, certificate issued within seven days, Trust Fund funded, agents contracted and the product opened.Fees paid, certificate in seven days.
Quick facts
RegulatorCentral Bank of Kenya
LawNPS Act 2011 · Regulations 2014
LicencePSP · e-money issuer · instrument issuer
Core capitalKES 5M / 20M / 50M · small e-money 1M
Client fundsTrust Fund (Regulation 25)
E-money limitsKES 70,000 a transaction · 1M a month
DecisionNo statutory deadline
Corporate tax30% · VAT 16%
Nothing in the Act or the Regulations obliges the central bank to decide by a given date. That is the argument for a file that answers the checklist before the first question round rather than after it.
Your Kenya desk
Run from our East Africa desk.
Prifinance - East Africa desk
Dubai · coordinating Kenyan mandates
33 Level, Al Saqr Business Tower, Dubai
01
Kenyan company formation
A locally incorporated company with the core capital at the Regulation 11 tier, the shareholding documented and the home-regulator no-objection collected where the owner is foreign.Local company, capital tier, no-objection collected.
02
The CBK file
Application, business plan, fit-and-proper forms, AML and cybersecurity documentation built against the central bank's own checklist and defended through the question rounds.Built against the regulator's checklist.
03
Trust and Trust Fund
The trust deed drafted, the trustee appointed and the bank or government-securities placements agreed before the authorisation is issued.Deed, trustee, placements before launch.
04
Substance in Nairobi
Directors and senior managers who pass the fit-and-proper test, a compliance function, premises and the reporting calendar running from day one.Fit-and-proper managers, compliance, premises.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Kenya.
A 30% corporate rate for a resident company and 37.5% for a branch, 16% VAT, and two charges that hit payment businesses directly: the digital service tax and excise on transfer fees.
Corporate tax 30%
The resident rate. A branch of a foreign company pays 37.5% on its Kenyan profits, which is usually the argument for incorporating locally rather than branching in.37.5% for a branch.
VAT 16%
The standard rate, with zero rating for Second Schedule supplies. Which parts of a payment product fall inside the exemption is mapped before pricing is set.Zero rating for Second Schedule supplies.
Dividends 10% and 15%
Withholding is 10% for residents, with no charge where a resident company holds more than 12.5%, and 15% for non-residents. Management fees and royalties abroad carry 20%.10% resident, 15% non-resident.
Digital service tax 1.5%
Section 12E of the Income Tax Act charges 1.5% of the gross transaction value. Draft regulations published in September 2025 would replace it with a significant economic presence tax; they are still draft.1.5% of gross transaction value.
Excise on transfer fees
The Excise Duty Act charges 20% on money-transfer fees taken by banks and money-transfer agencies and 12% on those taken by cellular phone service providers. Other fees charged by financial institutions carry 20%.20% banks, 12% cellular providers.
Payroll and treaties
PAYE and social contributions on Nairobi salaries, priced into the operating budget with the compliance and management hires, and a treaty network applied to outbound flows.20% on fees and royalties abroad.
Tax summary
Corporate tax30% resident · 37.5% branch
VAT16% · zero rating for Second Schedule supplies
Dividend withholding10% resident · 15% non-resident
Digital service tax1.5% of gross transaction value
Excise on transfer fees20% banks · 12% cellular providers
Other withholding20% management fees and royalties
*Figures as of 2026 per the Kenya Revenue Authority. The significant economic presence tax regulations published in September 2025 remain in draft. Treaty and regime positions are assessed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Kenyan company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed provider.
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The Kenyan payment licence, answered.
What licence does a payment business need in Kenya?+
Authorisation by the Central Bank of Kenya under the National Payment System Regulations 2014 - as an electronic retail payment service provider, an e-money issuer, an issuer of a designated payment instrument, or a small e-money issuer. The category follows the services you sell.
How much capital is required?+
Regulation 11 and Table A of the First Schedule: KES 5,000,000 for a retail payment service provider, KES 20,000,000 for an e-money issuer, KES 50,000,000 for an issuer of a designated payment instrument and KES 1,000,000 for a small e-money issuer. The capital is held at authorisation and at all times after.
How long does the central bank take?+
There is no statutory deadline in the Act or the Regulations. Regulation 5(3) lets the bank ask for more information within 30 days of the application, and Regulation 5(7) requires the certificate within seven days of the authorisation fees. Plan on eight to fourteen months from first call.
How is customer money protected?+
Regulation 25 requires a Trust and a Trust Fund whose balance is never less than what is owed to customers. The funds are placed in commercial banks licensed under the Banking Act or in Government of Kenya securities. The Fourth Schedule placement limits are cross-referenced but absent from the published text, so we obtain them for your case.
What are the e-money limits?+
Regulation 43 caps a single transaction at KES 70,000 and the monthly load at KES 1,000,000, and the central bank may approve higher limits. A small e-money issuer works to a KES 20,000 transaction limit with total e-money liabilities under KES 100 million.
Can an e-money issuer pay interest on balances?+
No. Regulation 44 requires redemption at par and bars the issuer from earning interest or any other financial return from the holder, and Regulation 45 rules out lending or investment beyond what the Regulations themselves require.
How large is the licensed market?+
The central bank's directory of authorised payment service providers at 17 June 2026 lists 43 providers. Nine are mobile-money issuers and three are infrastructure operators. M-PESA is the largest of them.
How are payment companies taxed?+
Corporate tax at 30% for a resident company and 37.5% for a branch, VAT at 16%, dividends at 10% for residents and 15% for non-residents. A payment business also meets the 1.5% digital service tax and excise of 20% or 12% on transfer fees.
Are agents allowed?+
Yes. Regulations 14 to 20 cover agents and cash merchants, including the contracts, the approvals and the provider's responsibility for what its agents do. Kenya has no passporting arrangement with its neighbours.
Why Kenya rather than Rwanda or Ghana?+
Kenya has the deepest mobile-money market and the lowest entry capital of the three at KES 5 million, but no decision deadline at all. Rwanda is cheaper to run and prints its licence fees; Ghana gives you 90 days in the statute and a five-year licence. Groups building an East African footprint usually start in Kenya and add Rwanda second.
Which licence?+
CBK authorisation: retail PSP, e-money, instrument issuer or small e-money.
Capital?+
KES 5M / 20M / 50M; small e-money KES 1M.
How long?+
No statutory deadline; 8-14 months realistic.
Client money?+
Trust Fund in licensed banks or government securities.
E-money limits?+
KES 70,000 a transaction, KES 1M a month.
Interest on balances?+
No - redemption at par, no return from the holder.
Market size?+
43 PSPs at 17 June 2026, nine mobile-money issuers.
Taxes?+
30% CIT, VAT 16%, DST 1.5%, excise 20% and 12%.
Agents?+
Yes - Regulations 14 to 20. No passporting.
vs Rwanda / Ghana?+
Deepest market, lowest entry, but no decision clock.
Client notes
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Founders who wanted it done right.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Central Bank of Kenya or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.