Know the borrower
Verify that the applicant is who they claim to be before disbursing, not after default.
Financial services
Financial services / Lending apps
Instant loans need instant, defensible identity checks.
Digital lenders must be licensed by the CBK. The CBK (Amendment) Act, 2021 brought digital credit providers under its supervision, and the Business Laws (Amendment) Act, 2024 widened this to non-deposit-taking credit providers, including buy-now-pay-later. Data protection enforcement against lenders has been active.
At a glance
Who sets the rules?
Primary regulator
Central Bank of Kenya (CBK)
Who this covers
Mobile loan apps, buy-now-pay-later providers, salary-advance and asset-finance lenders operating digitally.
Regulations that apply
CBK (Amendment) Act, 2021 and later amendments
CBK licensing and supervision of digital and other non-deposit-taking credit providers.
CBK (Digital Credit Providers) Regulations, 2022
Customer identification, credit pricing, disclosure, debt-collection conduct, complaints handling and AML compliance for licensed lenders.
Credit Reference Bureau Regulations, 2020
Rules on sharing and correcting borrowers' credit information.
Data Protection Act, 2019
Consent, purpose limits and a ban on misusing borrowers' contacts; the ODPC has fined lenders for debt-shaming.
POCAMLA, 2009
Customer due diligence, screening and suspicious-transaction reporting.
What you have to do
Lend responsibly
Assess affordability and disclose the full cost of credit up front.
Collect fairly
No threats, no contacting a borrower's phone contacts, and no sharing of debt information outside the rules.
Handle data lawfully
Collect only the data you need, with consent, and keep it secure.
Fraud to watch for
Borrowing in someone else's name
Stolen IDs and SIM swap used to take loans that the real person is then chased for.
Synthetic borrowers
Fabricated identities that build a short credit history and then default.
Loan stacking
One person borrowing across many apps under different identities.
How Sentinel helps
- ID and liveness checks in the loan sign-up flow, in seconds.
- Screening and duplicate-identity signals before disbursement.
- A record of each check to support disputes and CBK reviews.
Related reading
23 October 2026 · 4 min read
Digital lenders in Kenya: identity, licensing and data protection
Lending apps now sit under CBK licensing and active data protection enforcement. Here is what that means for identity checks in the loan flow.
Read the article 23 October 2026 · 4 min readDeepfakes and remote onboarding: what a liveness check has to prove
Face-swap video and replay attacks are now cheap. What institutions should expect from liveness and document checks, and why the record matters as much as the result.
Read the articleGeneral information, not legal advice. Last reviewed October 2026. Requirements change, so confirm the current position with the regulator or your counsel before relying on it.