Kenya Proposes Up to $1.93 Million Capital Requirement for Payment Firms
Kenya's financial regulator has proposed a capital requirement of up to $1.93 million for payment service providers operating in the country. The rule, if enacted, could exclude early-stage fintechs from the market and is being described as a potentially market-shaping barrier to entry.
Kenya Payments Bill: the sandbox is not a solution
The Central Bank of Kenya's draft bill sets KES 250 million — roughly $1.93 million — as the capital floor for electronic money issuers. And critically, borrowed money doesn't count: no shareholder loans, no convertible notes, nothing that isn't fully paid-up equity or disclosed reserves.
For a bootstrapped Kenyan fintech, that's not a high bar — it's a wall.
The bill does include a regulatory sandbox so early-stage firms can test products without a full licence. But a sandbox lets you experiment; it doesn't let you operate at scale, serve real customers, or build a real business. It's a waiting room, not a market.
Commercial banks, meanwhile, need only a CBK authorisation — not a full licence — because they already hold qualifying capital. So the bill that also proposes forcing banks to open their data simultaneously makes it harder for the fintechs that would benefit from that data to legally exist. Kenya is writing rules that open one door and quietly brick up another.
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