Class G Investor Permits in Kenya: Investment Thresholds, Evidence and the Licence-First Trap

The Class G work permit is the route most foreign founders use to relocate and run their own Kenyan company. It is also one of the more commonly misunderstood permits, because the figure everyone quotes, USD 100,000, does not actually appear in the regulation that creates Class G itself. Getting the sequencing and the evidence right matters more than memorising a number.

What Class G Actually Requires

The Seventh Schedule to the Kenya Citizenship and Immigration Regulations, 2012 defines Class G as available to a person who intends to engage, alone or in partnership, in a specific trade, business, consultancy or profession, other than a prescribed profession, in Kenya, and who satisfies three conditions: they have obtained any licence, registration or other authority necessary for the purpose; they have, in their own right and at their full and free disposition, sufficient capital and other resources for the purpose; and their engagement in the trade, business, consultancy or profession will be of benefit to Kenya. Nothing in that wording sets a specific shilling or dollar figure. “Sufficient capital” and “benefit to Kenya” are judged on the application before the Director of Immigration Services. The phrase “in their own right and at their full and free disposition” is doing real work in that first condition: capital that is borrowed, pledged as security elsewhere, or otherwise not genuinely available to the applicant does not satisfy it as readily as capital the applicant can show, through bank statements or audited accounts, is actually theirs to deploy into the Kenyan business.

Where the USD 100,000 Figure Actually Comes From

The widely quoted USD 100,000 threshold comes from a different statute entirely. Section 4 of the Investment Promotion Act sets the minimum investment for a foreign investor to be entitled to an investment certificate at USD 100,000 or its equivalent in any currency. Section 13 of the same Act then entitles the holder of an investment certificate to entry permits for expatriates connected with the investment. In other words, USD 100,000 is not a Class G eligibility figure at all; it is the amount that, once invested and certified, gives an automatic route to a permit through the investment certificate mechanism. An applicant who invests less than that can still apply for Class G directly on the “sufficient capital” test in the Seventh Schedule, but without the investment certificate’s automatic entitlement, the assessment is more discretionary and the file needs to work harder to establish that the capital and resources committed are genuinely sufficient for the specific business.

The Licence-First Trap

The first Class G condition catches out founders who try to apply for the permit at the same time as, or before, they finish licensing the underlying business. The Seventh Schedule requires that the applicant has already obtained any licence, registration or other authority necessary for the trade or business in question. For an activity that needs no separate business licence, this is straightforward once the company is incorporated. For a regulated activity, a digital credit business, for example, this means the sector licence itself should be in hand, or at least the incorporation and registration steps genuinely necessary to operate should be complete, before the Class G application is filed, not planned as a parallel or later step.

Government Fees

The Regulations’ own fee schedule sets the Class G application fee at KES 10,000 and the permit fee at KES 100,000. These are the government fees under the Regulations themselves and are separate from any legal fee for preparing the application. Fee schedules under subsidiary legislation are revised from time to time; confirm the current amount before budgeting, and see our guide to 2026 work permit fees for the fuller picture across all permit classes.

Entry Permits for Expatriate Staff via the Investment Certificate

Section 13 of the Investment Promotion Act does more than help the founder personally. The holder of an investment certificate is entitled to entry permits for expatriates connected with the certified investment, each issued for an initial two-year period. This is what allows a foreign-invested company to bring in a small number of key expatriate staff, not just the principal investor, once the investment certificate is in place, rather than each of them separately satisfying the Class G “sufficient capital” test in their own right. Confirm with current guidance exactly how many permits a given investment size entitles the holder to, since this depends on the certificate’s own terms.