There is no capital figure in the VASP Act 2025 itself, and there is no gazetted capital figure anywhere yet. The Act, in section 22, requires every VASP to stay in a “financially sound condition” by meeting whatever capital, solvency and insurance requirements are prescribed, but it leaves the actual shilling numbers to subsidiary Regulations. Those Regulations are still in draft. The draft Virtual Asset Service Providers Regulations, 2026, published for comment on 17 March 2026, propose a sliding scale of minimum core capital that runs from about KES 2.5 million for an investment adviser up to KES 500 million for a stablecoin issuer, with the categories in between graded by activity. A firm that wants more than one licence must hold separate paid-up capital for each licensed activity, so the figures add up rather than overlap. None of this is law yet. No Legal Notice gazetting the Regulations has appeared as of 30 June 2026, the figures can still change before they bind, and you cannot apply for a VASP licence in Kenya today.
Short answer
- The Act sets the duty, not the number. Section 22(1) requires capital, solvency and insurance “as may be prescribed”; the figures live in Regulations, not the Act.
- Draft range: from about KES 2.5 million (investment adviser) to KES 500 million (stablecoin issuer), graded by activity, in the draft 2026 Regulations.
- Stablecoins carry the heaviest floor: a draft KES 500 million minimum, plus a reserve rule (at least 30% in segregated Kenyan-bank accounts).
- Capital stacks per activity. Hold two licences, hold two lots of paid-up capital; the figures are not pooled.
- Not yet law. The draft Regulations are not gazetted as of 30 June 2026. Treat every figure here as a proposed direction, not a binding requirement.
- You cannot be licensed yet. CBK and CMA have jointly confirmed no VASP has been licensed; licensing opens only when the Regulations are gazetted.
For the full framework around licensing, AML, data protection and tax, start with the pillar: VASP licensing in Kenya. This guide goes deep on one thing only: how much capital you actually need to put up.
What does the VASP Act 2025 say about capital?
The Act handles capital at the level of principle and delegates the arithmetic.
Section 22(1) is the core duty. A VASP must “at all times maintain its business in a financially sound condition by complying with such capital, solvency and insurance requirements as may be prescribed”. That is three distinct obligations bundled into one clause: a capital floor, a solvency standard, and an insurance cover. Section 24(b) reinforces the capital limb as a continuing condition of the licence, requiring the VASP to “maintain and hold the prescribed capital requirements” for as long as it operates, not just at the application stage.
The word doing the heavy lifting is “prescribed”. Throughout the Act, “prescribed” means set in Regulations made by the Cabinet Secretary for the National Treasury. The capital, solvency and insurance numbers are therefore not on the face of the statute. They sit in the subsidiary Regulations the Cabinet Secretary has not yet gazetted.
The Act does, however, tell you one structural thing about how the numbers will work. It contemplates different figures for different activity types rather than a single flat number for all VASPs. That is consistent with the activity-based design of the whole regime: the First Schedule licenses eleven distinct activities across two regulators, and the prudential bar is meant to scale with the risk each activity carries. A custodian holding client coin and a stablecoin issuer holding fiat reserves do not present the same risk as an investment adviser who never touches client assets, and the capital scale is built to reflect that.
So at the level of the Act, the answer is settled in shape but open in number. The duty to hold capital is binding now. The amount is waiting on the Regulations.
What capital does the draft 2026 Regulations propose?
The first concrete numbers appeared with the draft Virtual Asset Service Providers Regulations, 2026, which the National Treasury published for public comment on 17 March 2026, with consultation running to 10 April 2026. As reported from the draft, the proposed minimum core capital is scaled by activity across the range below.
| Activity (illustrative band) | Draft minimum core capital | Regulator |
|---|---|---|
| Investment adviser | About KES 2.5 million | CMA |
| Other CMA market activities (broker, manager, advisory-type) | Mid-range, between the floor and the ceiling | CMA |
| Exchange, custody, payment processing | Higher mid-range | CMA or CBK by activity |
| Stablecoin issuer | KES 500 million | CBK |
Two cautions on this table. First, only the two endpoints are firm in the public draft: KES 2.5 million at the bottom for an investment adviser and KES 500 million at the top for a stablecoin issuer. The exact figure for each intermediate activity is part of the draft schedule and should be read off the gazetted text once it exists, not inferred from this guide. Second, every number here is draft.
[DRAFT, not yet law: the KES 2.5 million floor, the KES 500 million ceiling and every figure in between come from the draft Regulations 2026 and the Regulatory Impact Statement circulated for public comment to 10 April 2026. No Legal Notice gazetting the Regulations had been published as of 30 June 2026. The figures may change in the final text. Do not rely on any specific shilling figure in a binding context, a board paper or an investor deck until the Legal Notice is gazetted.]
The shape of the draft scale matters more than any single figure. It tells you the regulators intend the capital bar to track the activity’s exposure to client funds and to the wider financial system. Pure advisory sits at the bottom because the adviser never holds client assets. Stablecoin issuance sits at the top because the issuer holds fiat reserves backing a payment instrument that can scale across the economy. If you are modelling a launch, model the band your activity falls into, then add headroom for the figure to move when the draft is finalised.
Why is the stablecoin capital floor KES 500 million?
Stablecoin issuance carries the toughest terms in the whole draft regime, and the capital floor is only half of it.
The draft proposes a minimum core capital of KES 500 million for a stablecoin issuer. That is the single highest figure in the scale, roughly two hundred times the KES 2.5 million floor for an investment adviser. On top of that capital floor, the draft adds a reserve-backing rule: a stablecoin issuer must hold at least 30% of funds received in segregated accounts at Kenyan commercial banks, with the remainder in low-risk, Kenya-domiciled, high-quality liquid assets. The capital requirement and the reserve requirement are separate. The KES 500 million is the issuer’s own prudential cushion; the reserve is the backing held against the coins in circulation.
The logic is that a stablecoin is, functionally, a privately issued claim on fiat that circulates as money. If it loses its peg or the reserve is mismanaged, the damage is not confined to one firm’s clients; it can ripple through payments and into the banking system the reserve sits in. The Act’s own design supports a heavier bar here: stablecoin issuance is a separate, named activity under the First Schedule, supervised by the Central Bank of Kenya rather than the Capital Markets Authority, and the CBK is the regulator with the financial-stability mandate. Section 7 lists financial stability and market integrity among the guiding principles the regulators must weigh.
Industry groups warned during the consultation that the KES 500 million floor, combined with the fee scale, could push smaller Kenyan stablecoin projects offshore, where a comparable launch costs far less. Whether the final gazetted figure holds at KES 500 million or moves after the consultation is one of the open questions the draft leaves unresolved. For the detail on how stablecoins are regulated beyond capital, including the reserve composition, attestation and redemption rules, see Stablecoin regulation in Kenya.
[DRAFT, not yet law: the KES 500 million stablecoin floor and the 30% segregated-reserve rule are proposals in the draft 2026 Regulations, not gazetted requirements. The detailed reserve composition, attestation cadence and redemption-at-par timelines are also delegated to Regulations and not yet final.]
Do I need separate capital for each licence?
Yes, on the draft. This is the point founders most often miss, and it changes the maths for any multi-product business.
The draft Regulations propose that a firm holding more than one licensed activity must hold separate paid-up capital for each activity. The figures stack; they are not pooled and they are not netted. A business that wants to run both a custodial wallet and an exchange is looking at the custody capital figure plus the exchange capital figure, not the higher of the two.
This follows directly from the architecture of the Act. The regime licenses activities, not firms, and the First Schedule splits the eleven activities across two regulators. A combined wallet-plus-exchange business needs a CBK custody licence and a CMA exchange licence, two separate grants from two separate regulators. If the prudential bar is set per licence, the capital obligation is per licence too. The same is true of a broker that custodies client coin on the side: a CMA broker licence and a CBK custody licence, each with its own capital floor.
The planning consequence is concrete. If you are scoping a multi-product Kenyan VASP, build your capital model activity by activity from the start. Decide which activities you actually need a licence for, map each one to its regulator and its draft capital band, and sum the bands. A “we will just get the exchange licence and bolt on custody later” plan understates the capital requirement, because the custody licence brings its own floor. For how the eleven activities map to licence categories, see VASP licence categories in Kenya.
What about solvency and insurance, not just paid-up capital?
Capital is one of three financial requirements in section 22(1). The other two get less attention and are just as binding once the Regulations land.
Solvency is the ongoing condition. Paid-up capital is what you put in at the start; solvency is whether the business stays in a “financially sound condition” over time, which is the exact phrase section 22(1) uses. A VASP can meet its capital floor on day one and still breach the solvency standard later if its liabilities outrun its assets. Section 25 of the Act gives this teeth: the CEO has a personal statutory duty to notify the regulator of insolvency or likely insolvency, among ten other adverse events, with a written report and mitigation steps to follow. Solvency is monitored continuously, not just checked at licensing.
Insurance is the third limb. Section 22(1) lists insurance requirements alongside capital and solvency, which means a prescribed level of cover will be a condition of the licence. The specific minimums, by activity, are delegated to the Regulations and are not yet gazetted.
The prescribed insurance minimums per licence category, and the precise solvency ratio or net-asset test, are delegated to the Regulations and are not yet published. Insurance and the solvency formula are confirmed in principle by section 22(1) but remain unquantified until the Legal Notice is gazetted.
There is a related obligation that is not capital but sits next to it. Section 31 requires a custodian to hold a sufficient amount of each type of virtual asset to meet its obligations to clients, segregated from house assets and bankruptcy-remote from the licensee’s creditors. That is a client-asset reserve, not regulatory capital, but it is a real balance-sheet commitment that a custody business must fund on top of its own capital floor. Do not confuse the two: capital is the firm’s own cushion, the section 31 reserve is the client coin held in trust.
Are these capital figures final, or can they still change?
They can still change, and you should plan on the basis that they might.
The figures are draft. The status of the Regulations as of 30 June 2026 is straightforward and worth stating plainly. The draft Virtual Asset Service Providers Regulations, 2026 were published for public comment on 17 March 2026, the consultation closed on 10 April 2026, and no Legal Notice gazetting the final text has appeared on the public record since. Until that Legal Notice is published, the capital figures are proposals, not law, and they can be revised in response to the consultation, including the industry pushback on the KES 500 million stablecoin floor.
A second reason for caution: the licensing channel itself is not open. The Central Bank of Kenya and the Capital Markets Authority confirmed jointly on 18 November 2025 that no VASP has been licensed and that licensing will only begin once the Regulations are issued. So even a firm that can comfortably meet the draft capital figures cannot file an application today, because there is nothing to apply on and no capital threshold has been gazetted to apply against.
The practical posture is to scope now and capitalise on confirmation. Model your capital requirement against the draft band for your activity, build the figure into your funding plan with headroom, and be ready to confirm and top up the moment the Legal Notice is gazetted. The transitional window for existing operators closes on 4 November 2026, so the capital you need to raise is part of the same clock as the licence you need to file for. For the deadline mechanics, see VASP compliance deadline in Kenya.
Frequently asked questions
How much capital do I need for a VASP licence in Kenya? There is no gazetted figure yet. The Act, in section 22(1), requires capital, solvency and insurance “as may be prescribed” but leaves the amount to Regulations. The draft 2026 Regulations propose a scale from about KES 2.5 million for an investment adviser up to KES 500 million for a stablecoin issuer. Those figures are draft and not yet law as of 30 June 2026.
Is the KES 2.5 million to KES 500 million range final? No. It comes from the draft Virtual Asset Service Providers Regulations, 2026, published for comment on 17 March 2026 with consultation to 10 April 2026. No Legal Notice gazetting the Regulations has been published as of 30 June 2026, so the figures can still change.
Why is the stablecoin capital floor so high at KES 500 million? Because a stablecoin functions as privately issued money and its failure can ripple into payments and the banking system. It is supervised by the Central Bank of Kenya and carries the heaviest draft terms in the regime: a KES 500 million capital floor plus a reserve rule requiring at least 30% of funds received to be held in segregated Kenyan-bank accounts. Both are draft.
If I want two licences, do I add the two capital figures together? On the draft, yes. A firm holding more than one licensed activity must hold separate paid-up capital for each activity. The figures stack and are not pooled. A combined wallet-plus-exchange business needs the custody capital plus the exchange capital.
Is the capital figure in the VASP Act itself? No. The Act sets the duty in section 22(1) and section 24(b) but delegates the actual shilling amount to Regulations. You will not find a number in the statute; it lives in the subsidiary Regulations, which are not yet gazetted.
Does the capital requirement include client-asset reserves? No, those are separate. Regulatory capital is the firm’s own prudential cushion under section 22. The section 31 client-asset reserve is the requirement to hold a sufficient amount of each type of virtual asset a custodian holds for clients, segregated and bankruptcy-remote. A custody business funds both.
Can I apply for a VASP licence now if I have the capital ready? No. CBK and CMA confirmed jointly on 18 November 2025 that no VASP has been licensed and that licensing opens only once the Regulations are gazetted. There is no application channel and no gazetted capital threshold to apply against yet.
Does the capital have to stay in place, or is it just for the application? It must stay in place. Section 24(b) makes holding the prescribed capital a continuing condition of the licence, and section 22(1) requires the business to remain in a financially sound condition “at all times”. Solvency is monitored continuously, and the CEO must report likely insolvency under section 25.
If you are sizing the capital for a Kenyan crypto exchange, a custody business, a payment processor or a stablecoin issuer, the figure you raise depends on which activities you license and how the draft Regulations land. We model the capital stack activity by activity, flag where the draft figures are most likely to move, and build the funding plan around the transitional deadline so you are ready to file the moment the channel opens. Book a consultation and we will scope your capital requirement against your specific business.
Related reading: VASP licensing in Kenya, VASP licence categories in Kenya, Stablecoin regulation in Kenya, and VASP compliance deadline in Kenya.