Insights / Financial Services

Stablecoin Issuance in Kenya: What the VASP Regulations Actually Require

By Clay & Associates Advocates · 5 min read ·

Stablecoin Issuance Kenya — African fintech professional reviewing a digital currency platform on a tablet

Stablecoin Issuance Kenya is the practical starting point for anyone facing this situation, and it is where this article begins.

Kenya’s virtual asset regime treats stablecoins as their own thing entirely, not a variant of a wallet or exchange licence, but a separate Central Bank of Kenya category with its own application, its own white paper, and by far the heaviest capital and reporting burden in the whole regime. If your product is, or might become, a stablecoin, the rules are worth understanding on their own terms.

Stablecoin Issuance Kenya: What the Rules Actually Require

The detail below is what actually determines the outcome in most cases. www.centralbank.go.ke carries the official texts this is based on, and the rest of the article applies them to real situations.

A stablecoin licence is a different application, not an add-on

Regulation 67 of the Virtual Asset Service Providers Regulations, 2026 requires anyone issuing a stablecoin to apply to the Central Bank of Kenya specifically, on top of the general application requirements, with the issuer’s investment policy for its reserve assets, its redemption policy, and a stablecoin-specific white paper covering fifteen separate disclosure items under regulation 68, from the stabilisation mechanism to the environmental impact of the consensus protocol used. CBK has thirty days to decide once everything is in, the same clock as any other licence category, but the file it’s deciding on is considerably larger.

The reserve backing rules are strict, and specific

Regulation 75 requires every stablecoin to be fully backed at all times, reserve assets at least equal to the nominal value of every unit in circulation, and limits what can actually sit in that reserve: cash and CBK deposits, government securities maturing within 90 days, short-dated repurchase agreements, or anything else CBK specifically approves. Reserves for each stablecoin must be held separately from the issuer’s own operating assets and from the reserves backing any other stablecoin the issuer runs, and an issuer running more than one stablecoin has to keep entirely separate, separately managed pools for each. If the issuer becomes insolvent, regulation 75(g) and (j) insulate the reserve assets from the issuer’s creditors, they’re not available to satisfy the issuer’s own debts.

Most of the money has to sit inside Kenya

Regulation 77 is direct about this: at least 30% of funds received for stablecoin issuance must sit in trust accounts at commercial banks in Kenya, segregated specifically for processing issuance and redemption. The remainder still has to be invested in Kenya, under regulation 75’s asset rules. For a fiat-referenced stablecoin, the reserve currency has to match the currency the coin references, a shilling stablecoin’s reserves need to be in shillings. This is one of the more concrete “money stays local” rules anywhere in the regime, and it’s easy to miss if you’re modelling reserves the way you would in a jurisdiction without this requirement.

No interest, under any framing

Regulation 72 prohibits an issuer from granting interest to stablecoin holders, full stop, and goes further: any benefit tied to how long someone holds the stablecoin counts as interest regardless of what it’s called. This is a deliberate line between a stablecoin and a bank deposit or an investment product, and it rules out a fairly common feature in stablecoin products elsewhere (yield-bearing balances) as a matter of Kenyan law, not just product design choice.

Redemption is a right, not a feature

Under regulation 71, a holder can redeem at any time, at par value, and the issuer has two working days to pay out. Regulation 80 adds that if the issuer ever sold the stablecoin for Kenya shillings, it must always offer redemption in shillings too, an issuer can’t quietly steer holders toward a less convenient redemption currency. Redemption policies have to be clear, conspicuous, and disclosed up front in the white paper, not buried in terms updated later.

The reporting burden is the heaviest in the regime

Regulation 84 requires monthly reporting on holder numbers, circulation and peak values, transaction volumes, and any de-pegging events, all by the tenth of the following month, and separately, daily reconciliation reports on transaction volumes and reserve composition. Regulation 82 adds a quarterly independent audit of the reserve assets, and regulation 75(h) a quarterly stress test, both reported to CBK by the same tenth-of-month deadline. No other licence category in the Regulations carries daily reporting.

One more thing worth knowing if you’re an exchange, not an issuer

Regulation 83 gives CBK power to restrict, suspend, or delist a stablecoin’s trading or availability in Kenya, including a stablecoin issued entirely outside Kenya, by directing the licensed exchanges and wallet providers that make it available locally. If your business lists a major international stablecoin rather than issuing your own, you’re not the one holding a stablecoin licence, but you’re still the one CBK will direct if it decides that stablecoin needs restricting in the Kenyan market.

How We Can Help

Clay & Associates Advocates advises on Kenya’s Virtual Asset Service Providers Act and Regulations across all licence categories, including stablecoin issuance. See our guide to Kenya’s virtual asset licensing regime for how this category fits alongside exchange and wallet-provider licensing, and our step-by-step guide to the application process for what any application, stablecoin or otherwise, actually requires. Contact our regulatory and compliance practice to discuss a stablecoin application.

Sources: Virtual Asset Service Providers Regulations, 2026 (Legal Notice 134), regulations 67, 68, 71, 72, 75, 76, 77, 80, 82, 83, 84, Fifth Schedule.

Frequently asked questions

Do I need a stablecoin licence just to list an existing stablecoin like USDT on my exchange?
No. Regulation 67 applies to issuing a stablecoin, not trading one someone else issued. Listing a third-party stablecoin falls under your exchange or wallet-provider licence instead, though regulation 83 still gives CBK power to restrict that stablecoin’s availability through you.

Can stablecoin holders earn interest or yield?
No. Regulation 72 prohibits it outright, and treats any length-of-holding-based benefit as interest regardless of how it’s labelled.

How quickly must redemption requests be honoured?
Within two working days, at par value, under regulation 71(3).

What happens to reserve assets if the issuer becomes insolvent?
Regulation 75 requires reserve assets to be legally segregated from the issuer’s own estate specifically so that the issuer’s creditors have no claim on them in an insolvency.

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Clay & Associates Advocates
This article is general information, not legal advice. For advice on your matter, speak to counsel.

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