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FNJ analysis · Updated as new annual reports are released

Kenya 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.

BreachRuleDec 2024Dec 2025
Commercial banks in breach of the Banking Act or Prudential GuidelinesAll1135
Credit pricing not in line with the Risk-Based Credit Pricing ModelCBK pricing modelNot reported33 penalised; 2 administrative actions
Single obligor limit of 25% of core capitalBanking Act s.10(1)910
Minimum core capital (KES 1bn in 2024; KES 3bn in 2025)Banking Act s.7(1)37
Total capital below 14.5% of risk-weighted assetsBanking Act s.18; CBK/PG/0355
Core capital below 10.5% of risk-weighted assetsCBK/PG/03Included above4
Core capital below 8% of depositsCBK/PG/0343
Large exposures above 5 times core capitalCBK/PG/07 cl.3.353
Shareholding above 25% by one personBanking Act s.13(1); CBK/PG/0733
Board compositionCBK/PG/02 cl.3.4.6Not reported3
Single insider borrower limit of 20% of core capitalBanking Act s.11(1)(f)22
Land and buildings above 20% of core capitalBanking Act s.12(c)22
Foreign exchange exposure above 10% of core capitalCBK/PG/0622
Statutory liquidity ratio below 20%Banking Act s.19(1)31
Total insider borrowing above 100% of core capitalBanking Act s.11(1)(g)11
Transfer of 5% shareholding without CBK approvalBanking Act s.13(4)Not reported1
Microfinance banks2025
Microfinance banks below the capital adequacy requirements5 of 14
Microfinance banks below the 20% liquidity minimum2

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.

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.

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How 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.