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Fintech & payments

VASP 2026 Transition & Licensing Readiness Checklist

An editable Kenyan VASP readiness workbook covering activity classification, regulator route, capital, governance, policy documents and implementation evidence before the 4 November 2026 transition deadline.

Free working resourceEditable Word document (.docx)KenyaReviewed 17 August 2026
Who it is for
  • Existing virtual-asset businesses assessing the 4 November 2026 transition deadline
  • Exchanges, custodial wallets, brokers, payment processors, stablecoin and token businesses
  • Boards, founders, legal, compliance, risk, finance and technology teams coordinating an application
What it does not do
  • Concluding that an activity is licensed, exempt or outside the Kenyan perimeter
  • Treating a checklist as the regulator's complete application form or current direction
  • Predicting whether, when or on what conditions CBK or CMA will grant a licence
What is included

A structured starting point you can control.

  1. 01

    CBK and CMA activity map with multi-licence and perimeter questions

  2. 02

    Paid-up-capital reference, corporate structure, governance and fit-and-proper evidence

  3. 03

    Nine board-approved policy workstreams plus AML/CFT, custody, technology and conduct controls

  4. 04

    Evidence register and a board-owned 30/60/90-day transition implementation plan

Use offline; do not upload confidential information.

The resource is designed to be downloaded and completed within your own controlled environment. It is a general working aid, not legal advice, a compliance certification, an executable agreement or a prediction of any regulator’s decision.

Primary sourcesVirtual Asset Service Providers Act, 2025↗Virtual Asset Service Providers Regulations, 2026↗Proceeds of Crime and Anti-Money Laundering Act↗
Related guidance and servicesVASP licensing and regulatory readiness in KenyaKenya's final VASP Regulations — practical guideAML/CFT programmes for fintechs
When the facts need judgment

Turn the completed working aid into a defined legal mandate.

Send a short, non-confidential scope request. The firm ordinarily responds within one business day and will confirm conflicts, engagement terms, scope and fees before substantive review.

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Important notice.

No duty to update this resource is assumed. Check current official sources and obtain advice on the complete facts before acting. Read the full disclaimer.