Is Your Digital Credit Business CBK-Compliant? A Practical Checklist for Licensed Digital Credit Providers

As Kenya’s digital lending market continues to mature, the Central Bank of Kenya (CBK)
has intensified its regulatory oversight of Digital Credit Providers (DCPs). Newly licensed
DCPs face an increasingly complex compliance landscape spanning consumer
protection, data privacy, anti-money laundering, corporate governance, credit reporting,
and regulatory reporting. Failure to comply may expose providers to regulatory sanctions,
financial penalties, licence suspension or revocation, and reputational risk.
To assist market participants, we have developed a practical CBK Regulatory Compliance
Checklist designed to help DCPs assess their compliance obligations under the Central
Bank of Kenya Act, the Digital Credit Providers Regulations, 2022, the Data Protection Act,
2019, and related regulatory guidance. The checklist provides a structured framework for
reviewing key compliance areas, including licensing and governance, consumer
protection, data protection, AML/KYC controls, credit reference reporting, CBK reporting
obligations, and pricing compliance.
Our Financial Services, Consumer Protection and Dispute Resolution team regularly advises
digital lenders, financial institutions and fintech businesses on regulatory compliance,
licensing, governance, investigations, enforcement actions, consumer claims and financial
services litigation. If you would like a copy of the checklist or require a confidential
compliance health check, please contact us.
This publication is intended for general information purposes only and does not constitute legal advice. It should not be relied upon as a substitute for specific legal advice on any particular matter. Regulated entities should seek independent legal counsel on the application of the frameworks described herein to their specific circumstances.