Agent Banking In Kenya: Your Rights At A Bank Agent (2026)

What agent banking actually is

A bank agent is a shop that has been contracted by a bank to handle certain banking transactions on that bank's behalf. The hardware shop in the trading centre with an Equity or KCB sign above the door is not a branch and is not a bank. It is an ordinary business — with its own stock, its own landlord and its own licence — that has signed an agency contract and been approved by the Central Bank of Kenya to serve that bank's customers over the same counter.

The framework is the Central Bank of Kenya's Guideline on Agent Banking, CBK/PG/15, issued under section 33(4) of the Banking Act and in force since 1 May 2010. It is short, it is public, and it is unusually specific about what the shopkeeper may and may not do to you. Most Kenyans have used an agent hundreds of times without ever reading it, and the gap costs them money — because several of the things agents routinely do are things the guideline forbids.

Two words in the guideline matter. An agent is an entity "contracted by an institution and approved by the Central Bank". Both halves are required. A contract alone does not make a legal agent, and a shop cannot appoint itself.

Who is allowed to be a bank agent

CBK/PG/15 lists the entity types eligible for appointment: limited liability companies, sole proprietorships, partnerships, societies, co-operative societies, state corporations, trusts and public entities. It then explicitly excludes others — an entity that is faith-based or not-for-profit, a non-governmental organisation, an educational institution, a forex bureau, or any entity that under any applicable law may not carry on profit-making business, cannot do agent banking.

The bar for an individual shop is higher than most people assume. Before a bank may even apply to CBK for your local agent, it must satisfy itself that the business:

• has held a valid business licence for a lawful commercial activity, and has actually been trading, for at least eighteen months immediately preceding the assessment, with that activity ongoing;
• has not been classified as a deficient, doubtful or non-performing borrower by any institution in the preceding 18 months — and must keep that clean status for the life of the contract;
• has the physical premises, staff and cash to do the work securely.

The bank also vets the owner personally: criminal record in matters of finance, fraud or integrity, negative credit-bureau information, sources of funds, business track record, and character references from two people of good standing who have known them at least three years and come from the same locality.

CBK charges the bank KSh 5,000 for the one-off agent-network application and KSh 1,000 per agent or outlet approved. Approval lasts one year and must be renewed at KSh 1,000 per outlet; a bank that pays late owes double, and one that is more than ninety days late has the renewal declined outright. This is why an agent can vanish overnight — the licence is annual and the bank, not the shopkeeper, controls it.

One more useful fact: agency contracts cannot be exclusive. A single shop may serve several banks at once provided it has a separate contract with each and genuinely has the float and the space to manage them. The counter serving three bank brands is normal, not suspicious.

What an agent can and cannot do for you

The permissible list in CBK/PG/15 is closed — an agent may only do what the guideline allows and what its own contract with the bank specifically agrees. Permitted services include cash deposit and cash withdrawal, cash disbursement and cash repayment of loans, cash payment of bills, cash payment of salaries, cash payment of retirement and social benefits, transfer of funds, balance enquiry, mini statements, collection of completed account-opening, loan and card application documents, collection of debit and credit cards, cheque book requests and collection, and agent mobile phone banking services.

The prohibited list is where your protection lives. An agent shall not:

• open an account, grant a loan, or carry out any appraisal for opening an account or granting a facility — it may only collect your completed forms and pass them on;
• transact in foreign currency — every monetary transaction through an agent must be denominated in Kenya shillings;
• provide cash advances, offer any guarantee, or deal in cheque deposits and encashment;
• carry out a transaction when a receipt or acknowledgement cannot be generated, or when the system is down;
• offer banking services on its own account, or hold itself out as providing services not in its contract;
• be run or managed by an employee or associate of the bank, or subcontract the agency to somebody else;
• charge any fees directly to customers.

That last one deserves its own section.

The rule most Kenyans do not know: the agent cannot charge you

"Ongeza fifty" is not a service charge. It is a breach of the guideline.

CBK/PG/15 prohibits an agent from charging any fees directly to the customer, and separately requires that every agency contract between a bank and an agent contain a clause prohibiting the agent from charging the customer any fees. The agent is paid by the bank — remuneration for the agent is another mandatory clause in that contract.

Be precise about what this does and does not mean, because the honest version is more useful than the slogan. It does not mean agent banking is free. Your bank may levy its own charges for a deposit, withdrawal or transfer, and those are legitimate. What is prohibited is the agent adding a private top-up of its own on the side. The guideline settles the distinction in your favour at the counter: among the things an agent must display conspicuously is "the list of charges or fees applicable for each service which are payable to the institution by the customers". If a charge is real, it is on the wall and it goes to the bank. If it is not on the wall and it goes into the shopkeeper's pocket, it is not a charge — and you can report it.

This is worth internalising because agent charges are one of the quiet leaks in a Kenyan household budget, in the same family as the M-Pesa costs covered in our guide to managing money on M-Pesa. A hundred shillings skimmed twice a month is KSh 2,400 a year, which is more than the annual return on a small savings balance at many banks.

What must be on the wall

Clause 9.3.1 of the guideline lists what an agent must disclose in a conspicuous place on its premises. Use it as a checklist the first time you use an unfamiliar agent:

1. The name and logo of the institution it is working for.
2. The list of banking services the agent offers.
3. A written notice that no transaction will be carried out when the electronic system is down.
4. A written notice that services are subject to availability of funds.
5. The list of charges payable to the bank for each service.
6. The dedicated telephone line for contacting the bank.
7. The name, telephone number and location of the bank branch the agent reports to.

Beyond the wall, the agent must have signs clearly visible to the public showing it provides the services of that bank — and it must not represent to the public that it is itself an institution. Banks may brand their agent networks however they like, but protected words such as "bank", "finance", "financial institution" or "financial intermediary" cannot be used in a way suggesting the agent is a bank.

And the strongest right of the lot: on request, an agent must show you a copy of the CBK approval letter, a copy of its appointment letter from the bank, and the current licence for its commercial activity. The guideline says these should be readily available on the premises. An agent that cannot produce them is an agent you should not hand cash to. Separately, banks are required to publish an updated list of all their agents on their websites, so a doubtful agent can be checked before you travel there — the same verify-first habit that protects you from the fake lenders in our guide to spotting an unlicensed loan app.

How big the network really is

The Central Bank's Bank Supervision Annual Report 2024 gives the honest scale. During 2024, 16 commercial banks had contracted 89,167 bank agents, and 5 microfinance banks had contracted 539. The commercial bank figure was up 1,636 agents (1.9%) on the 87,531 recorded at the end of 2023; the microfinance agent network shrank by 20.4%.

The concentration is extreme. Over 90% of approved bank agents sat with just three banks — Equity Bank with 37,704 agents, KCB Bank Kenya with 23,336, and Co-operative Bank with 18,207. If you bank elsewhere, the agent on your street corner very likely does not serve your bank, which is a practical thing to weigh when comparing bank accounts or switching banks.

Volumes are enormous but no longer growing. Agents handled 142.3 million transactions in 2024, down 2.1% from 145.3 million in 2023 — CBK attributes the fall to competition from mobile money and internet banking. Value moved the other way, up 3.2% to KSh 1.70 trillion. Cumulatively since 2010, agents have processed just over 1.5 billion transactions worth KSh 13.26 trillion.

The mix tells you what agents are actually for. Of the 2024 transactions, 67.2 million were cash deposits and 38.9 million were cash withdrawals, but only 10,637 were fund transfers and 145,685 were mini statements. Dividing the value tables by the volume tables gives an average deposit of roughly KSh 21,100 and an average withdrawal of roughly KSh 6,565. Agents are a cash-in and cash-out network — a way to move physical notes into and out of a bank account without travelling to a branch. For anything else, the branch, the app or a money transfer service will usually serve you better.

When the system is down or a transaction fails

Every deposit, withdrawal, payment or transfer through an agent must settle in real time. There is no "I will post it later". If the network is down, the agent is required to stop — and the guideline separately forbids transacting whenever a receipt or acknowledgement cannot be generated.

The equipment itself carries obligations. Agent devices must be able to reverse incomplete transactions caused by error, system failure or power outage; produce a durable receipt or acknowledgement, for which an SMS is acceptable; generate an audit trail; and automatically log the agent off once its daily cash limit is exhausted or it attempts an unauthorised transaction. So an agent whose float has run out is genuinely locked out — that is the system working, not the shopkeeper being difficult.

If your money leaves your account but no cash reaches your hand, the reversal duty sits with the bank's systems, not with the shopkeeper's goodwill. Call the bank's dedicated line, quote the transaction, and keep the receipt. The process is closer to a bank dispute than to the mobile-money route described in our guide to reversing a wrong M-Pesa transaction.

Who is liable when it goes wrong

This is the single most important clause in CBK/PG/15, and it is unambiguous. Every agency contract must state that the institution is wholly responsible and liable for all actions or omissions of the agent — and that this responsibility extends to actions of the agent even if they were not authorised in the contract, so long as they relate to banking services or matters connected with them.

You do not chase the shopkeeper. You claim against the bank. A bank cannot answer a complaint about its agent by saying the agent went off-script, because the guideline anticipated exactly that answer and closed it.

The complaints machinery is specified too. Banks must provide a dedicated customer-care telephone line for lodging complaints — and that same line can be used to verify an agent's authenticity, physical location and the validity of its agent banking business. Banks must run a complaints redress mechanism, communicate it to customers, and address every complaint within a reasonable time and in any case not later than thirty days from the date it is lodged. They must keep records of all complaints and how they were resolved, and report monthly to CBK — by the 10th of the following month — on transaction volumes, incidents of fraud, theft or robbery, and customer complaints with the remedial measures taken.

Where CBK finds non-compliance it can revoke an agent's approval, direct termination of the agency contract, bar a bank from contracting new agents, or stop it doing agent banking altogether.

Agent banking is not the same as an M-Pesa shop

The two counters often sit side by side, sometimes in the same shop, and Kenyans use "agent" for both. Legally they are different things. A bank agent under CBK/PG/15 acts for a licensed bank and touches your bank account. A mobile-money agent operates within the separate framework governing payment service providers and touches your mobile-money wallet. The rights described in this article — the no-own-fee rule, the CBK approval letter, the bank's full liability, the 30-day complaints deadline — attach to the bank-agent relationship.

The money-safety consequence is worth stating plainly: cash sitting in a bank account is covered by deposit insurance, as explained in our guide to KDIC deposit protection; a balance in a mobile wallet is protected by a different arrangement. Depositing through an agent puts the money in the bank; leaving it in the wallet does not.

Simple habits that keep you safe

• Never share your PIN with anyone, including the agent. The guideline makes the point explicitly: customers must be made aware not to store their PIN carelessly or share it with other parties "including agents". An agent who asks for your PIN is committing fraud, not offering help.
• Insist on the receipt. It is not a courtesy. The agent must issue one for every transaction, and is forbidden from transacting at all if one cannot be generated.
• Check the balance before you leave the counter, using your own SMS or app rather than the agent's screen.
• Expect to be identified. Agents must identify customers using at least two-factor authentication — an ID plus a PIN, card, secret code or secret message. Being asked for ID is compliance, not obstruction.
• Refuse the private fee, and if it is demanded, note the agent's name and location and call the bank's dedicated line.
• For large sums, use the branch. Agent float is finite and limits are set per agent by each bank; a big withdrawal is a wasted trip more often than not.

Agent banking has genuinely widened access to banking in Kenya, and for routine cash-in and cash-out it saves a real journey. But it is a thin channel by design: no accounts opened, no loans granted, no foreign currency, no cheques, no advances. Treat it as the cash window of your bank rather than as the bank itself, and use the branch, the app or a savings account for everything that is not moving notes.

Frequently asked questions

Can a bank agent legally charge me a fee? No. CBK/PG/15 prohibits an agent from charging any fees directly to customers, and requires every bank-agent contract to contain that prohibition. Your bank may charge its own fee for the transaction, and that tariff must be displayed on the agent's premises. Anything demanded over and above the displayed bank charge is not permitted.

How do I check that an agent is genuine? Ask to see the CBK approval letter, the appointment letter from the bank, and the agent's current business licence — the guideline says these must be readily available on the premises and shown on request. You can also call the bank's dedicated customer-care line to verify the agent's identity, location and validity, or check the agent list the bank is required to publish on its website.

Can I open a bank account at an agent? No. Opening accounts, granting loans and carrying out any appraisal for those purposes are on the prohibited list. An agent may collect your completed account-opening or loan application documents and pass them to the bank, but the decision and the account opening happen at the bank. The same applies to cards: an agent may hand over a debit or credit card, not approve one.

The agent took my deposit but it has not reflected. Who is responsible? The bank. Every agency contract must state that the institution is wholly responsible and liable for all actions or omissions of its agent, including actions not authorised in the contract. Lodge the complaint with the bank on its dedicated line, keep your receipt, and note that the bank must address the complaint within a reasonable time and no later than thirty days.

Can an agent handle dollars or other foreign currency? No. Agents are prohibited from transacting in foreign currency, and the guideline requires that all monetary transactions conducted through an agent be denominated in Kenya shillings. Foreign-currency business belongs at a branch or a licensed forex bureau — and a forex bureau is itself barred from being a bank agent.

Why did the agent refuse to transact when the network was down? Because they must. Agents are prohibited from carrying out an electronic transaction during a communication failure, and from transacting at all when a receipt or acknowledgement cannot be generated. All agent transactions must settle in real time, so there is no compliant way to record it now and process it later.

Can one shop serve several banks? Yes. No agency contract may be exclusive. A shop may act for multiple institutions provided it holds a separate contract with each and the banks are satisfied it has the space, technology and float to manage the volumes.

Reviewed 30 August 2026 against the Central Bank of Kenya's Guideline on Agent Banking (CBK/PG/15) and the CBK Bank Supervision Annual Report 2024. Agent numbers and transaction figures are the latest published by CBK and describe 2024. Bank tariffs and per-agent limits are set by each bank and change — confirm the current charges on the tariff displayed at the agent or with your bank.

This article is general information, not financial advice.