Proposal for Digital Credit Provider (DCP) Registration and Licensing in Kenya

This document outlines the procedural steps and documentary requirements for the three main stages of the Digital Credit Provider (DCP) licensing process, as mandated by the Central Bank of Kenya (Digital Credit Providers) Regulations, 2022.

Stage 1: Preliminary Clearance and Company Incorporation

The first stage is designed to establish the proposed DCP entity and obtain the necessary preliminary clearances from both the Registrar of Companies and the Central Bank of Kenya (CBK).

Phase 1: Name Reservation and Company Details Submission (e-Citizen & BRS)

This phase establishes the entity’s legal foundation and prepares the first set of documents required for the CBK submission.

Step No.	Action	Responsible Authority	Output/Deliverable
1.1	Submit a minimum of three (3) proposed company names via the e-Citizen portal under the Business Registration Service (BRS).	Registrar of Companies	Name Approval/Reservation Document.
1.2	Finalize collection of all Director, Shareholder, and Beneficial Owner information, including KRA PIN and identification documents (National ID/Passport).	Applicant	Internal Documentation

Phase 2: Initial Approval and “Letter of No Objection” (Central Bank of Kenya)

The CBK requires a submission of key business intent and shareholder fitness documentation before the Certificate of Incorporation is issued. This submission is made to the CBK Registration and Bank Supervision Department.

Required Documents for Initial CBK Submission (Per the initial query):

1. Name Reservation Document.
2. Shareholder and Director Identification: Names, addresses, and certified copies of identification documents.
3. High-Level Business Brief (3-5 Pages): Detailing the business model, target market, and shareholder background.
4. Capital and Source of Funds: Initial capital and documentary evidence of the sources of funds.
5. Declaration of Sources of Funds: Formal statutory declaration by each shareholder, certified by an Advocate or Commissioner of Oaths.

Deliverable:

• Upon review and satisfaction by the CBK, the bank will issue a Letter of No Objection.

Phase 3: Finalization of Private Limited Company Registration

With the CBK Letter of No Objection, the process returns to the Registrar of Companies for the formal incorporation of the Private Limited Company.

Step No.	Action	Document Used	Final Deliverable
3.1	Submit the mandatory registration forms (e.g., CR1, CR2, CR8, BOF1) along with the CBK Letter of No Objection to the Registrar of Companies.	CBK Letter of No Objection	Company Registration Certificate.
3.2	Apply for the list of Directors and Shareholders.	Registrar of Companies	CR12 Certificate (Proof of ownership and directors).

Phase 4: Tax Compliance Setup (Kenya Revenue Authority – KRA)

Upon successful incorporation, the company must register with the Kenya Revenue Authority (KRA) to establish tax obligations.

Step No.	Action	Authority	Purpose
4.1	Apply for the Company KRA PIN Certificate online via the iTax platform using the Certificate of Incorporation.	KRA	Tax Identification
4.2	Register for applicable tax obligations (e.g., Income Tax, VAT, PAYE).	KRA	Tax Compliance
4.3	Apply for the Tax Compliance Certificate (TCC).	KRA	TCC is a mandatory document for the final CBK license application in Stage 2.

Stage 2: Full License Application Submission (Central Bank of Kenya)

This stage involves the submission of the comprehensive license application package, including all legal, governance, operational, and compliance documents, to the CBK.

Phase 5: Online Profile Creation and Form Generation (CBK Portal)

Step No.	Action	Authority	Purpose
5.1	Create the company profile on the CBK’s online portal using the company’s registered email address.	CBK Portal	Establish Application Account
5.2	Complete the online application, generating the CBK DCP 1 form for signing by the Directors.	CBK Portal	Core Application Form
5.3	Download, complete, and execute the Fit and Proper Forms (CBK DCP 2 and 3) for all Directors, the Chief Executive Officer, Senior Officers, and Significant Shareholders.	CBK Portal / Applicant	Fitness & Propriety Assessment
5.4	Scan and upload the duly signed CBK DCP 1, and the executed CBK DCP 2 and 3 forms.	CBK Portal	Submission Start

Phase 6: Comprehensive Supporting Document Submission

The following documents must be scanned and uploaded to the CBK online portal to support the application:

Category	Requirement
Legal Status	* A certified copy of the Certificate of Incorporation of the applicant.
	* A certified copy of the Memorandum and Articles of Association (M&A) of the applicant.
	* A certified copy of the M&A of any corporate body that has a significant shareholding in the applicant.
	* A certified copy of the constitutive documents of an unincorporated body that has a significant shareholding in the applicant.
Technology & Product	* Description of the Information and Communication Technology (ICT) system to be used in operations, including an independent assurance on the systems.
	* Description of, and terms and conditions of credit products and services the applicant intends to provide.
	* Agreement with a telecommunication or other service provider for the provision of the channel or platform for digital credit.
Compliance & Governance	* The applicant’s Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) policies and procedures.
	* The applicant’s data protection policies and procedures.
	* The applicant’s consumer redress mechanisms, policies, and procedures.
	* Credit policy, code of ethics and market conduct.
	* The applicant’s pricing model and parameters.
	* Corporate governance policy.
Individual Compliance	* Certificate of Good Conduct, Tax Compliance Certificate (TCC), and a recent (not more than three months old) Credit Reference Bureau (CRB) report for each individual significant shareholder, director, and senior officer.

Completion of Phase 6 officially concludes the document submission phase for the Digital Credit Provider license.

Stage 3: Data Submission Testing and Licensing (Central Bank of Kenya)

This final stage confirms the technical operational readiness of the DCP, collects the final regulatory fee, and results in the formal issuance and publication of the license.

Phase 7: Regulatory Testing, Fee Payment, and Final Issuance

This final phase focuses on confirming the applicant’s technical readiness and completing the financial formalities prior to receiving the official DCP license.

1. Regulatory Data Submission Testing: Once the CBK is satisfied with the assessment from Stage 2, the applicant will be required to test their data submission capability (Regulatory reporting) using Application Programming Interfaces (APIs), with guidance from the CBK.
2. Payment of Prescribed Licence Fees: Upon official notification by the CBK, the applicant must pay the prescribed license fees as specified under the Fourth Schedule of the DCP Regulations (currently 20,000). The fee is payable in full for the year and is not prorated for validity periods less than 12 months.
3. Licence Issuance: Upon fulfillment of all licensing requirements and successful data submission testing, the CBK will issue the official Digital Credit Provider licence.
4. Public Notification: The CBK shall cause the name of the newly licensed Digital Credit Provider to be published in the Kenya Gazette and on the Central Bank of Kenya’s official website.