Charting a Course for a Resilient Kenyan Credit Market: Lessons from the CIS Kenya Credit Market Growth Summit 2025

The New Macro Reality

The summit opened with a stark macroeconomic overview presented by Jared Osoro, an Economist and Member of the Central Bank of Kenya’s Monetary Policy Committee. The key message was that the current global economic climate presents a new set of challenges that are fundamentally different from those of the past. With a significant portion of global GDP coming from governments that are prioritizing industrial policy over free markets, the spillover effects are felt in Kenya through multiple channels, including trade, finance, and geopolitics.

This heightened policy uncertainty demands a deep look into the future design of our monetary and financial systems, one that embraces innovation while preserving the trust fundamental to economic stability. For lending institutions, this global picture necessitates constant recalibration of their growth strategies.

Data, Quality, and the Future of CIS

The conversations drilled down into the heart of the credit market; the Credit Information Sharing (CIS) system. Our CEO, Jared Getenga, delivered a keynote address on the evolution and future of the CIS system and its profound contribution to Kenya’s credit market. He set the stage for one of the summit’s most eye-opening sessions, a panel discussion he moderated featuring the CEOs of Kenya’s three licensed Credit Reference Bureaus (CRBs): Morris Maina the CEO of TransUnion, Kamau Kunyiha the CEO of Creditinfo, and Gideon Kipyakwai the CEO of Metropol.

The panel tackled the most pressing issues at the core of modern lending. The CEOs candidly discussed that the foundation of a resilient credit market is trustworthy data. Without reliable and high-quality data, the entire system of risk assessment falters. Moving beyond traditional data, the panellists emphasized the need to integrate alternative data sources as a means of deepening financial inclusion for credit invisibles. They provided the CRB perspective on risk-based pricing, explaining how rich, granular data allows lenders to move away from broad-stroke pricing models and offer credit that more accurately and fairly reflects individual borrower risk.

The future-focused part of the discussion centered on the adoption of Artificial Intelligence and Machine Learning in credit markets. The consensus was that these technologies are essential for analyzing vast datasets to create more predictive risk models, though their adoption must be managed responsibly to ensure fairness and transparency. This session underscored a unified message that the future of credit in Kenya hinges on a collaborative effort to enhance the quality, depth, and intelligent application of data.

Deconstructing VUCA in the Kenyan Financial Sector

Joseph Githaiga, Partner at Spencer West (Kenya), provided a detailed review of the implication of VUCA on the legal and regulatory framework that govern the credit market in kenya .The perspective include:

• Volatility: The rapid speed and magnitude of change in laws and policies, such as the frequent amendment of tax laws that have introduced sudden excise duties on loan fees and a rapid reversal of the Digital Asset Tax.
• Uncertainty: The lack of clarity on applicable rules or how they will be enforced. This is evident when courts strike down new tax provisions, introducing uncertainty over whether to comply or await final rulings, or when key concepts like “suspicious transactions” in AML laws lack bright-line standards.
• Complexity: The sheer proliferation of rules and the compliance burden they introduce. Interfacing with multiple financial sector regulators—CBK, CMA, ODPC, FRC, KRA, SASRA, and the IRA—each with separate reporting formats is complicated. This is compounded for regional players facing different country-specific data protection laws.
• Ambiguity: Situations where the proper course of action is unclear despite the presence of laws. Vague definitions for terms like “digital asset transaction” in tax statutes or “high-risk AI” force legal and compliance teams to interpret gray areas, risking inadvertent non-compliance.

These challenges lead to practical consequences, including decision paralysis, significant resource strain from overlapping controls, and escalating compliance costs.

Confronting the Fraud Epidemic

In a keynote address, Michael Nyaga, Chief Product Officer at Creditinfo, painted a stark picture of the Kenyan fraud landscape, which has seen a staggering 860 million reported cyberattacks in the past year and suffers an estimated 3.6% loss of GDP due to weak AML controls. A CBK survey further revealed internal institutional challenges, with 56% reporting inconsistent screening and 48% being unaware regarding the low adoption of anti-fraud technology.

The solution lies in deploying a robust fraud risk management framework that focuses on prevention, detection, investigation, and remediation, using multi-signal insights to establish trust and pinpoint fraud at the onboarding stage.

The subsequent panel discussion moderated by Lemuel Mangla and featuring Michael Nyaga and Hannah Ndarwa, the Head of Legal at CIS Kenya, delved into practical strategies, highlighting the need for financial institutions to move beyond traditional bureau services and leverage new solutions for scoping both external and internal fraud threats. The panel explored CRB-led risk management solutions that leverage multi-signal insights, combining digital footprints, identity verification, and watchlist screening, to establish trust and pinpoint fraud at the onboarding stage.

A critical point of discussion was the balance between driving financial inclusion and ensuring financial health for consumers. The consensus was that robust, data-driven fraud prevention is essential to safely onboard new customers, thereby protecting not only the financial ecosystem but also the long-term well-being of the newly included consumers. Ultimately, redefining consumer trust in the digital age requires a proactive, layered defense system.

Enhancing Risk Strategies and Financial Inclusion

TransUnion CEO, Mr. Morris Maina highlighted that access to reliable and comprehensive data is fundamental to achieving financial inclusion. Enhanced data allows institutions to develop comprehensive profiles of previously “invisible” consumers, facilitating their entry into the formal financial system. The CreditVision suite, for instance, enables more accurate credit decisions by using trended data and powerful analytics to identify resilient consumers who can drive profitable growth. This allows lenders not just to avoid risk, but to find and fund good consumers prudently, even in uncertain times.

The Challenge of Consumer Education and Technological Advancement

A recurring theme was the dual-edged nature of technology. While AI and machine learning are being adopted in credit markets, they also introduce ambiguity around concepts like “meaningful human oversight.” This technological leap necessitates a parallel leap in consumer education. The Bureau’s solutions overlay include “consumer education + anti-fraud alerts,” recognizing that an informed consumer is the first line of defence. The challenge of financial inclusion is evolving into one of ensuring financial health, which requires consumers to understand the products they are using and the data they are sharing.

The Data-Driven Response: From Risk to Resilience

In a VUCA world, the historical approach to credit risk is no longer sufficient. The presentations from leading credit bureaus underscored that the path to resilience is paved with data and advanced analytics.

1. Enabling Quicker, Smarter, and Responsible Credit Risk Decisions: In his session, Moses Koriko, Product Manager at TransUnion, demonstrated how to enable quicker, smarter, and responsible credit risk decisions across the entire customer lifecycle. The key is to leverage enhanced data not just for underwriting, but for pre-delinquency management and collections as well.

TransUnion’s CreditVision® suite, for example, utilizes over 145 enriched attributes built on trended credit data to provide a 360-degree view of the consumer. This allows lenders to analyse behavioural patterns like payment ratios, balance shifts, and spending habits over time, which are powerful indicators of future performance. This is complemented by the globally recognized FICO® Score, which has been locally tailored for Kenya to provide a consistent, data-driven approach to evaluating risk.

By using these tools, lenders can move beyond simple risk avoidance. The goal is to “find good and fund good consumers” prudently by identifying resilient customers who can drive profitable growth. Furthermore, trended data helps predict potential first-time defaulters, allowing for proactive engagement to reduce the delinquent pool and enabling data-driven collection strategies that optimize resources.

A Blueprint for Action

The summit was not just about diagnosing challenges but about forging a path forward. Joseph Githaiga outlined a clear blueprint for mitigating legal and regulatory risks, which serves as a strategic summary for the entire ecosystem:

• Engage Regulators Early: Don’t wait for rules to be finalized. Financial institutions must maintain open communication with authorities, participate in regulatory sandboxes, and join industry forums like CIS Kenya to help shape new rules.
• Build Regulatory Foresight: Establish dedicated teams to track draft laws, circulars, and global standards. Running board-level “what if” scenarios on potential shocks like new taxes can build institutional resilience.
• Embed Compliance Agility: Move away from rigid compliance frameworks. Instead, invest in modular RegTech, conduct regular risk assessments, and create rapid-response squads that can act on pre-approved playbooks when regulations change.
• Foster a Customer-First Culture: The ultimate mitigation is to build a business model centered on fairness and transparency. Ethical lending and robust data practices can pre-empt harsh regulation and build the customer trust needed to thrive long-term.

Conclusion

The Credit Market Growth & Resilience Summit made it clear that the Kenyan credit market is navigating a complex and demanding new chapter. The challenges of VUCA are real, but they are not insurmountable. By embracing a strategy founded on regulatory foresight, data-driven decision-making, and a steadfast commitment to ethical practices, Kenya’s financial institutions can not only weather the storm but emerge more resilient, innovative, and inclusive than ever before. As the convener of this vital dialogue, CIS Kenya remains dedicated to promoting these best practices and fostering the collaboration needed to build a more open and sustainable credit market for all.