KENYA Law and Practice Contributed by: Sammy Ndolo, Njeri Wagacha, Brian Muchiri and Valere Nyaboke, Cliffe Dekker Hofmeyr
Cliffe Dekker Hofmeyr 3rd Floor Block D Merchant Square Riverside Drive Nairobi Kenya Tel: +254710560114 Email: cdhkenya@cdhlegal.com Web: www.cliffedekkerhofmeyr.com
1. Fintech Market 1.1 Evolution of the Fintech Market Key Developments
els to deliver faster, more accessible loans to individu - als and small businesses. Since the introduction of the licensing framework in March 2022, the CBK has received over 800 applica - tions, signalling strong market demand and illustrating the rapid growth of digital credit activities. Mobile money dominance Mobile money remains the dominant pillar of Kenya’s financial ecosystem, showing sustained growth in both penetration and usage. According to the Com - munications Authority of Kenya (CA), mobile money subscriptions reached 47.7 million active accounts by June 2025, equivalent to approximately 91% popula - tion penetration – up significantly from about 77.3% the previous year. This growth reflects continued consumer uptake and the critical role of mobile wallets in everyday financial activity. Mobile money now supports a wide range of transactions beyond peer‑to‑peer transfers, includ - ing bill payments, merchant payments and savings. This expansion has helped deepen financial inclusion across both urban and rural areas. Data from the CBK and sector reports indicate that mobile money trans - actions continue to record high volumes and values, even where macroeconomic conditions influence fluc - tuations in transaction values. Looking Forward Regulatory spotlight Over the next 12 months, Kenya’s fintech sector is expected to shift from rapid product experimenta -
Kenya’s fintech market has strengthened its position as a continental leader, driven by ongoing innovation, regulatory progress, and growing adoption of digital financial services. The following developments have shaped the country’s fintech landscape over the past 12 months. Enactment of the Virtual Asset Service Providers Act The Virtual Asset Service Providers Act (VASPA) came into force on 4 November 2025. The Act establishes a licensing and supervisory framework for virtual asset service providers (VASPs). Under the new regime, applicants must demonstrate financial soundness, strong governance and risk‑management structures, robust cybersecurity controls, and compliance with fit‑and‑proper requirements. VASPA also sets out ongoing obligations for licensed VASPs, including safeguarding customer assets, maintaining ethical and market‑conduct standards, and complying with anti‑money laundering and coun -
ter‑terrorism financing laws. Growth of digital lending
Digital lending continues to expand rapidly. In 2025, the Central Bank of Kenya (CBK) licensed approxi - mately 110 digital credit providers, bringing the total number of licensed entities to 195. These lenders rely on data analytics and alternative credit‑scoring mod -
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