Kenya’s asset management industry runs on regulatory trust, and that trust starts with a single document: the fund manager licence. Issued by the Capital Markets Authority (CMA), this licence is the gatekeeping requirement for any firm that wants to manage collective investment schemes, unit trusts, or discretionary portfolios on behalf of Kenyan investors. Anyone weighing the cost of entry into this market needs to understand exactly what a fund manager licence will cost, both upfront and every year after.
Why the Fees Changed
For more than two decades, CMA charged a flat annual fee for every licensed fund manager, regardless of how much money the firm managed. That changed with the Capital Markets (Licensing Requirements) (General) Regulations, 2025, which replaced the old flat-rate system with a tiered, asset-based model. Under the new Sixth Schedule, a fund manager licence now carries charges that scale with the size of the business, not a one-size-fits-all number.
Application, Licensing, and Annual Fees
| Charge | Old Structure | 2025 Regulations |
|---|---|---|
| Application fee | Nominal flat fee | Set per the Sixth Schedule |
| Licensing fee | Flat fee | Set per the Sixth Schedule |
| Annual regulatory fee (collective investment schemes) | Flat Ksh 150,000 | 0.05% of assets under management, minimum Ksh 100,000, maximum Ksh 15 million |
| Annual regulatory fee (non-CIS managers, excluding pension funds) | Flat fee | 0.01% of AUM, capped at Ksh 15 million |
The shift to an AUM-based model means a small new entrant pays close to the old minimum, while an established fund manager overseeing tens of billions of shillings could see its fund manager licence bill climb into the millions annually. Industry estimates suggest the largest players could eventually pay as much as Ksh 339 million a year once the new fee structure is fully phased in.
Capital Requirements Tied to the Licence
A fund manager licence is not just about fees. The 2025 Regulations also doubled the minimum shareholders’ funds requirement for licensed fund managers, from Ksh 10 million to Ksh 20 million, to be maintained at all times during the licence period. This higher capital threshold is meant to strengthen the financial resilience of firms holding a fund manager licence and protect investors in the underlying schemes.
Transition Period
CMA has not switched the new charges on overnight. Existing holders of a fund manager licence have a grace period running until 11 December 2026 to meet the revised capital and fee requirements, giving firms roughly a year to adjust budgets, raise additional capital, or restructure operations.
Checklist Before You Apply
- Confirm whether your firm falls under the collective investment scheme category or the non-CIS category for your fund manager licence, since the fee formulas differ
- Budget for the application fee, licensing fee, and the first year’s annual regulatory fee separately
- Raise shareholders’ funds to at least Ksh 20 million before submission
- Apply for in-principle approval first; the 2025 Regulations allow a six-month window to build systems and hire staff before full licensing
- Track your projected assets under management, since your fund manager licence fee is recalculated against AUM each year
- Set a reminder for the December 2026 compliance deadline if you already hold a licence under the old regime
Getting It Right
The cost of a fund manager licence in Kenya is no longer a fixed line item; it is a variable that grows with your business. Firms entering the market, or renewing under the new framework, should work with a compliance advisor or directly with CMA’s licensing department to confirm the current fee schedule before submitting an application, since regulatory charges can be revised again as Parliament finalises outstanding details of the 2025 Regulations.
