Kenya is proposing significantly different minimum capital requirements for payment companies under a new National Payment System Bill, with the largest requirement reaching KSh250 million, or roughly $1.93 million. The proposal is part of a wider effort to modernise regulation of the country’s fast-growing digital payments industry.
The National Treasury and Central Bank of Kenya (CBK) published the draft National Payment System Bill 2026 on September 21, alongside a draft national payment system policy. The proposed legislation would replace Kenya’s existing National Payment System Act and introduce a broader regulatory framework covering payment service providers and payment system operators.
Under the bill’s Third Schedule, the capital requirements vary according to the services a company provides. Electronic money issuers would face the highest threshold at KSh250 million. Merchant acquirers and electronic wallet providers would each require at least KSh50 million, while money remittance service providers would need KSh30 million.
For payment system operators, the proposed minimum capital ranges from KSh10 million for payment gateways to KSh20 million for payment messaging system operators. Card scheme operators and payment switching and clearing system operators would each require KSh50 million.
At the lower end, payment initiation service providers and account information service providers would each require minimum capital of KSh5 million.
The structure reflects an attempt to match financial requirements with the nature and potential risks of different payment businesses. Companies responsible for issuing electronic money or handling significant payment infrastructure would have higher capital buffers than providers offering narrower services.
The proposed requirements come as Kenya’s payments ecosystem becomes increasingly diverse. Banks now compete alongside mobile-money platforms, fintechs, payment processors, digital wallets and other technology-driven providers. The draft policy says the new framework is intended to support interoperability, innovation, financial inclusion and competition while strengthening consumer protection and financial stability.
Capital requirements are only one part of the proposed regulatory overhaul. The bill also contains provisions covering licensing, governance, consumer protection, data protection, insolvency and administrative enforcement. It would give the CBK broader oversight of payment service providers and payment system operators.
The legislation could therefore have implications for both established payment companies and startups seeking to enter the market. Higher capital thresholds may require some businesses to raise additional funding before obtaining or maintaining a licence, while the tiered structure could allow smaller specialised providers to operate with lower requirements.
However, the figures remain proposals rather than current legal obligations. The CBK has invited public comments on the draft bill and policy, meaning the requirements could change before legislation is enacted.
For Kenya’s fintech sector, the proposed KSh250 million threshold signals a regulatory shift toward requiring payment businesses to demonstrate stronger financial capacity as the digital payments market becomes more interconnected and systemically important.
The debate now is likely to focus on how Kenya can strengthen resilience and consumer protection while ensuring that new capital requirements do not unnecessarily restrict innovation or competition in one of Africa’s most developed digital payments markets.
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