Research / Financial sector supervision / Tracker
FNJ analysis · Updated as new annual reports are releasedKenya Financial Regulator Enforcement Tracker
Breaches, penalties and other supervisory action disclosed by Kenya's financial regulators in their annual reports. Institutions are counted by type rather than named.
Coming soon · Sources: CBK, SASRA and CMA annual reports
The latest year at a glance
35
commercial banks in breach of the Banking Act or Prudential Guidelines at the end of 2025, up from 11 a year earlier
CBK Bank Supervision Annual Report 2025, s.3.18
33
banks penalised after CBK inspected how they price loans under the risk-based credit pricing model
CBK Bank Supervision Annual Report 2025, s.3.18
39
deposit-taking SACCOs on conditional licences or other interventions for weak institutional capital in 2025
SASRA Sacco Supervision Annual Report 2025, p.85
33
enforcement actions taken by the Capital Markets Authority in 2024/25
CMA Annual Report 2024/25
Banks and microfinance banks
Source: CBK Bank Supervision Annual Reports 2024 and 2025, section 3.18 (Compliance with Supervisory and Regulatory Requirements) and section 3.19. Breaches as at 31 December. One bank can appear under several breaches.
| Breach | Rule | Dec 2024 | Dec 2025 |
|---|---|---|---|
| Commercial banks in breach of the Banking Act or Prudential Guidelines | All | 11 | 35 |
| Credit pricing not in line with the Risk-Based Credit Pricing Model | CBK pricing model | Not reported | 33 penalised; 2 administrative actions |
| Single obligor limit of 25% of core capital | Banking Act s.10(1) | 9 | 10 |
| Minimum core capital (KES 1bn in 2024; KES 3bn in 2025) | Banking Act s.7(1) | 3 | 7 |
| Total capital below 14.5% of risk-weighted assets | Banking Act s.18; CBK/PG/03 | 5 | 5 |
| Core capital below 10.5% of risk-weighted assets | CBK/PG/03 | Included above | 4 |
| Core capital below 8% of deposits | CBK/PG/03 | 4 | 3 |
| Large exposures above 5 times core capital | CBK/PG/07 cl.3.3 | 5 | 3 |
| Shareholding above 25% by one person | Banking Act s.13(1); CBK/PG/07 | 3 | 3 |
| Board composition | CBK/PG/02 cl.3.4.6 | Not reported | 3 |
| Single insider borrower limit of 20% of core capital | Banking Act s.11(1)(f) | 2 | 2 |
| Land and buildings above 20% of core capital | Banking Act s.12(c) | 2 | 2 |
| Foreign exchange exposure above 10% of core capital | CBK/PG/06 | 2 | 2 |
| Statutory liquidity ratio below 20% | Banking Act s.19(1) | 3 | 1 |
| Total insider borrowing above 100% of core capital | Banking Act s.11(1)(g) | 1 | 1 |
| Transfer of 5% shareholding without CBK approval | Banking Act s.13(4) | Not reported | 1 |
| Microfinance banks | 2025 |
|---|---|
| Microfinance banks below the capital adequacy requirements | 5 of 14 |
| Microfinance banks below the 20% liquidity minimum | 2 |
The CBK reports that "appropriate remedial actions were taken" on the banks concerned. It does not publish penalty amounts or the banks' names. Since 2025, the Banking (Penalties) Regulations allow penalties of up to three times any gain made or loss avoided through a breach.
SACCOs
Source: SASRA Sacco Supervision Annual Report 2025, sections 4.4, 6 and 8.5.
| Indicator | 2024 | 2025 |
|---|---|---|
| Deposit-taking SACCOs below 8% institutional capital to total assets, on conditional licences or other supervisory interventions | Not stated (143 complied) | 39 (140 complied) |
| Deposit-taking SACCOs below 10% core capital to total assets | 5 | 5 |
| Non-deposit-taking SACCOs below 8% core capital to total assets | 44 | 16 |
| Non-deposit-taking SACCOs below 50% retained earnings and reserves to core capital | 62 | 58 |
| Licences or authorisations ended (one voluntary merger, one failure to renew) | Not read | 2 |
| On-site compliance inspections | 48 | 41 |
SASRA lists the interventions it uses on SACCOs that fall short: conditional licences and restrictions on dividends, interest on members' deposits, board honoraria and staff bonuses. The report does not give penalty amounts.
Capital markets
Source: CMA Annual Report 2024/25. The CMA publishes no separate annual supervision report.
| Indicator | FY2024/25 |
|---|---|
| Enforcement actions taken by the Capital Markets Authority | 33 |
Breakdown by type of licensee and breach is added once read from the full report.
What it means
- Loan pricing is now the most common breach. Following inspections across all commercial banks, the CBK penalised 33 and took administrative action against 2; only 3 were fully compliant.
- Breaches of the minimum core capital rose from 3 banks to 7 as the minimum rose from KES 1 billion to KES 3 billion.
- In SACCOs, 39 deposit-takers are operating under conditional licences or other interventions because their institutional capital is below 8% of assets.
How FNJ can help
Regulatory compliance reviews against the Banking Act, Prudential Guidelines and SACCO regulations, internal audit of credit pricing, capital and governance, and capital plans for SACCOs under conditional licences.
Book a 15-minute callHow we build the tracker
- All figures are drawn from the regulators' annual reports: the CBK Bank Supervision Annual Report, the SASRA Sacco Supervision Annual Report, and the CMA Annual Report.
- Press releases, press coverage and industry figures are used only to check ours, never quoted.
- We report numbers and types of institution only. Institutions and individuals are never named.
Disclaimer
This tracker is general information based on reports published by Kenya's financial regulators. It is not legal or financial advice. Confirm figures against the original reports before relying on them. FNJ & Associates accepts no liability for decisions made on the basis of this tracker.