Kenya National Payment System Bill 2026 Sets New Capital Rules

In Short

Kenya’s National Payment System Bill, 2026 proposes new Central Bank of Kenya licensing rules for payment firms. Minimum capital could range from KES 5 million to KES 250 million. The draft could make fundraising slower for some fintechs because only certain forms of capital would count.

What Happened

The National Payment System Bill, 2026 is a draft law that would replace Kenya’s 2011 payments law and expand how the Central Bank of Kenya, or CBK, regulates payment service providers.

Under the proposal, payment firms would need a CBK licence and would also need to meet minimum capital thresholds based on the payment activity they offer. Electronic money issuers, firms that hold customer funds in a wallet-like account, face the highest stated minimum at KES 250 million.

The draft also introduces a stacking rule for companies that want more than one licence category. A firm would need the full minimum for its highest category, plus 50% of the minimum for each additional category.

A key detail is what counts as qualifying capital. The draft would require fully paid-up ordinary shares and disclosed reserves. That excludes shareholder loans, convertible debt, and other borrowed funds, financing tools startups often use while they grow.

The Treasury and CBK published the draft on September 21, 2026 and invited public comments, with a deadline of October 9. As of October 15, it remained a proposal and would still need cabinet and parliamentary steps to become law.

If enacted, existing providers would have 12 months from commencement to comply.

Why It Matters

If capital must be equity and retained reserves, some Kenyan fintechs may need to raise more dilutive rounds, or wait longer to build reserves, before they can qualify for a CBK licence. The draft also includes CBK approval requirements around investments into payment companies, which could add time and process to fundraising.

There is some potential relief for early-stage teams. The bill proposes a regulatory sandbox, a supervised testing environment that can let firms pilot new payment products without immediately meeting full licensing and capital requirements.

For founders, operators, and investors in Kenya’s payments market, the next signal to watch is how the final bill defines capital, timelines, and which activities sit in each licence category.