USDT and USDC are the most used crypto assets in Kenya, the dollar rail behind most peer-to-peer trades and cross-border payments. Under the Virtual Asset Service Providers Regulations, 2026, a licensed Kenyan exchange cannot list either of them. Regulation 60(6) is one sentence long and it reshapes how Kenyan exchanges, wallets and their users deal with dollar stablecoins. This article explains what it says, who it binds, and what it leaves open.
What regulation 60(6) says
Regulation 60 sets the listing rules for virtual asset exchanges and token issuance platforms. Sub-regulation (6) provides that a virtual asset exchange shall not list any stablecoin unless that stablecoin has been approved by the Central Bank of Kenya and is issued by a duly licensed stablecoin issuer.
Both conditions must be met. CBK approval of the coin alone is not enough; the issuer must also hold a Kenyan stablecoin issuance licence. USDT and USDC meet neither condition. Their issuers are not licensed in Kenya and the CBK has not approved the coins.
What a licensed stablecoin issuer looks like
The bar is deliberately high. A stablecoin issuer applies to the CBK under regulation 67 with its reserve investment policy, redemption policy and a white paper. The Fifth Schedule sets paid-up capital at KES 300 million, the highest of any licence category, with liquid capital of KES 60 million or 100% of current liabilities for 30 days, whichever is higher.
Once licensed, the issuer must:
- issue at par on receipt of funds and redeem at any time on request (regulation 71);
- pay no interest to holders, and no licensee may grant interest on stablecoin services (regulation 72);
- hold at least 30% of funds received in segregated trust accounts at Kenyan commercial banks (regulation 77).
A global dollar issuer with reserves in US treasuries and bank deposits abroad is not going to restructure for the Kenyan market. In practice, regulation 60(6) means Kenyan exchanges list only Kenyan-licensed stablecoins, and none existed when the transition period closed on 4 November 2026.
Who the rule binds, and who it does not
Regulation 60(6) is addressed to a “virtual asset exchange”. It does not, on its terms, bind wallet providers, payment processors or brokers. That matters because the Regulations elsewhere assume offshore stablecoins will circulate. Regulation 83(2) lets the CBK, where a stablecoin is issued outside Kenya, direct licensed intermediaries operating in Kenya to restrict access to or trading of that stablecoin. A power to restrict presupposes that access exists in the first place.
The likely reading is a two-track system:
- Listing for trading on a Kenyan exchange: Kenyan-licensed stablecoins only.
- Custody and transfer by licensed wallet providers and payment processors: offshore stablecoins are not banned outright, but the CBK can restrict them at any time under regulation 83.
That reading is ours, not the regulator’s. A wallet provider planning USDT custody for Kenyan users should seek CBK comfort before launch.
Practical consequences
For exchanges. USDT and USDC trading pairs have to come off a licensed exchange’s order book. Bitcoin and other assets remain listable, subject to the due diligence in regulation 33 and the subscription condition in regulation 60(3). Dollar settlement now needs a different route.
A related point deserves attention. Regulation 60(3) says an exchange may only include a virtual asset in its list where the asset has attained the minimum subscription disclosed in a white paper approved by the CMA for its initial offering and listing. Read literally, that would also block assets such as bitcoin, which never had a Kenyan white paper. The provision was almost certainly written with Kenyan token offerings in mind, but exchanges should get the CMA’s view in writing rather than assume it.
For peer-to-peer markets. Most Kenyan stablecoin volume runs through offshore peer-to-peer desks. Regulation 60(6) does not reach those platforms directly, but regulation 4 may: an offshore platform targeting Kenyans or earning income from Kenya is treated as operating in or from Kenya and needs a licence. We cover that test in our article on offshore crypto platforms serving Kenyans.
For businesses using stablecoins for payments. Converting virtual assets to or from foreign currency needs a separate CBK authorisation under regulation 14. See our guide on converting crypto to foreign currency.
For anyone promoting a stablecoin. Regulation 70 separately bars anyone from offering a stablecoin to the public or seeking its admission to trading unless they are its licensed issuer and the CBK has approved its white paper, which has been published. Breach attracts the administrative sanction in regulation 142.
Will this change?
There is a reasonable policy case for allowing foreign stablecoins whose issuers are regulated under an equivalent regime, such as the US GENIUS Act or the EU’s MiCA, with disclosure and concentration limits in place of Kenyan reserve rules. Nothing in the Regulations provides for that today. Until it does, exchanges should plan around the rule as written.
How We Can Help
Clay & Associates Advocates advises exchanges, wallet providers and prospective stablecoin issuers on listing policy, CBK engagement and licence applications. Our article on stablecoin issuance in Kenya covers the issuer licence in detail. Contact our financial services team to discuss your listing or custody plans.
Related reading: our articles on token listing due diligence under regulation 33.
Sources: Virtual Asset Service Providers Regulations, 2026 (LN 134 of 2026), regulations 4, 14, 33, 60, 67, 70, 71, 72, 77 and 83 and the Fifth Schedule; Virtual Asset Service Providers Act, 2025, First Schedule.
Frequently asked questions
Can a Kenyan exchange list USDT or USDC?
No. Regulation 60(6) bars a licensed exchange from listing any stablecoin unless the CBK has approved it and a Kenyan-licensed issuer issues it.
Is it illegal for Kenyans to hold USDT?
No. Regulation 60(6) governs what exchanges list, not what individuals hold. The CBK can, however, direct licensed intermediaries to restrict access to offshore stablecoins under regulation 83.
Can a licensed wallet provider custody USDT?
The listing bar does not expressly apply to wallet providers, but the CBK can restrict offshore stablecoins at any time. Seek CBK comfort before launching.
What capital does a stablecoin issuer need in Kenya?
KES 300 million paid-up capital and liquid capital of KES 60 million or 100% of current liabilities for 30 days, whichever is higher.
Need advice on your own matter?
Tell us what you are dealing with. You will know what it involves and what it costs before you commit.
This article is general information on Kenyan law as at its publication date, not legal advice. Reading it does not create an advocate and client relationship.



