Corporate Account Opening Requirements in Kenya: Documents, BRS Official Search (CR12), Beneficial Ownership and Signatories

Short answer: To open an account for a Kenyan company, a bank needs evidence of incorporation, the memorandum and articles, a certified board resolution naming the signatories, the registered office, the people who manage, control or own the company, financial statements, the company's KRA PIN and its beneficial owners (POCAMLA s.45(1A)(b); POCAML Regulations reg 16). Partnerships, trusts, PBOs and societies swap in their own registration documents.

This guide is for account-opening, operations and compliance teams at Kenyan banks, microfinance banks and SACCOs who set the document list for business customers. It separates what the law requires from what banks commonly add. This is a practical guide, not legal advice; confirm requirements with your supervisor (CBK, SASRA) or adviser. Checked against primary sources on 8 October 2026.

What does Kenyan law require for every business customer?

Three texts set the minimum:

• POCAMLA s.45. Institutions identify and verify each customer from "an official record reasonably capable of establishing the true identity" (s.45(1)). For a body corporate, s.45(1A)(b) lists evidence of registration or incorporation, the Act establishing it (for statutory bodies), and a corporate resolution authorising a person to act, with a copy of the latest annual return. A government department presents a letter from its accounting officer and the National Treasury's authorisation (s.45(1A)(c)).
• The POCAML Regulations 2023. Reg 16 gives the list for legal persons, reg 17 partnerships, reg 18 trusts, reg 22 beneficial owners and reg 23 anyone acting for the customer. They apply to every reporting institution (reg 3).
• Supervisory guidance. CBK's 2025 Guidance on Customer Due Diligence restates reg 16 for banks, microfinance banks and other CBK-licensed institutions (para 3.3.2); see our guide to CBK's 2025 customer due diligence guidance. SACCOs follow SASRA/GG/1/2024.

Due diligence applies whatever the amount (CDD para 3.2). If the evidence is not produced as soon as reasonably practicable, do not open the account, and file a suspicious transaction report (reg 25(2); CDD para 5.1).

The regulation 16 list for a company

CBK's guidance cites regs 16(g) and (h) for financial statements; in the regulation they are 16(f) and (g). Cite the regulation.

What is the BRS official search (CR12), and is it required?

What most people call "the CR12" is the BRS official search. On eCitizen, BRS lists it as "Official Search (Formerly 'Cr12')": a computer-generated certificate of the company's directors and shareholders. BRS's July 2023 guide says only companies with "Verified" status generate an automated search.

• The statutory Form CR 12 is a different document. Under LN 103 of 2017 it is a notice of a company secretary's residential address. Write "BRS official search (CR12)" on your forms.
• We found no statute that requires a "CR12". The duty comes from CBK's Guidance on Beneficial Ownership: banks collect a copy of the CR12 and of the BO form filed with BRS, and match the beneficial owners' names against both (para 4.6.1).

Your policy should say how recent a search you accept.

What does each type of business need to provide?

A few types need more care.

Partnerships and LLPs. Partnerships, including limited partnerships, sit with the Registrar of Companies (Partnerships Act 2012). CBK's CDD guidance lists LLPs among the BRS-registered legal persons (para 3.3.2), so confirm with your supervisor whether you apply reg 16 to them as well as reg 17.

PBOs and NGOs. The PBO Act commenced on 14 May 2024 and repealed the NGO Co-ordination Act (s.70). An NGO may present a PBO certificate or a certificate issued under the repealed Act; the transition is contested, so confirm your approach with your supervisor.

Societies, clubs and groups. We found no rule in the 2023 Regulations for unincorporated associations, clubs or chamas, and s.45(1A)(b) covers only bodies corporate. CBK's BO guidance points to office bearers instead (para 4.4). Chamas have their own guide: chama account opening requirements.

SACCOs as customers. CBK's BO guidance lists co-operative societies among the entities whose beneficial owners must be determined (para 4.1), and for cooperatives points to office bearers, senior management and members with effective control (para 4.4). Confirm the registration document with your supervisor. Onboarding a SACCO's own members is covered in SACCO member onboarding under SASRA.

Trusts. The Trust Administration Act 2026 commenced on 25 September 2026 and repealed the Trustees (Perpetual Succession) Act (s.99(1)). Written trusts must be registered or incorporated (s.5(2)) with the Registrar of Trusts at BRS (s.77(1)); their names end "Registered Trust" or "Incorporated Trust" (ss.24(2), 30(1)). The trustee must disclose that status when forming the relationship (reg 18(3)). Existing trusts have twenty-four months to comply (s.99(2)(b)), so certificates under the repealed Act will keep arriving until around September 2028. Treat them as transitional.

Is a KRA PIN required to open a business account?

Yes. The Tax Procedures Act lists "Opening accounts with financial institutions and investment banks" among the transactions that require a PIN (First Schedule item (11); s.13(1)(b)), and reg 16(1)(h) asks for the entity's PIN. Since the Finance Act 2026, non-residents are exempt when opening an account (s.12(5B)).

"PIN certificate" is KRA's name for the document, not a statutory term. CBK gives a KRA PIN name check as an example of verification, not a requirement (CDD Table 3); see IPRS and KRA PIN checks.

For individual directors and signatories, the Regulations treat the PIN as an optional extra "if such a number has been issued" (reg 15(2)(h)). Banks commonly ask for it anyway: I&M's published group checklist (July 2025) asks for a certified KRA PIN for every signatory.

Who can act for the business: the board resolution and signatories

1. Proof of authority. For a company, a certified board resolution authorising the account and naming the signatories (reg 16(1)(d)). For other customers, CBK accepts a notarised or registered power of attorney, a signed letter of authorisation stating its scope and duration, a partnership agreement or LLP deed, or a trust deed or trustee resolution (CDD para 3.4.2).
2. Verification of the people. Verify that anyone acting for the customer is authorised, and identify and verify them (s.45(3); reg 23). Each goes through full due diligence.
3. Capacity. Check legal capacity (for example, not a minor) and that no court injunction or regulatory ban applies (CDD para 3.4.2).

The mandate itself ("any two to sign", limits) follows the company's articles and your form. See our guides to the board resolution for opening a bank account and authorised signatories and signing mandates.

Beneficial ownership: what to collect

Reg 22(1) requires institutions to "identify and verify the natural persons behind a legal person". POCAMLA and the Regulations set no percentage. The 10% figure comes from the Companies (Beneficial Ownership Information) Regulations, reg 3(2): at least 10% of the shares or voting rights, the right to appoint or remove a majority of the board, or significant influence or control. We found no 25% threshold in any Kenyan primary source.

CBK asks for each owner's name, ID or passport copy, date of birth and nationality, the BRS official search (CR12), the BO form filed with BRS and an ownership chart. Banks match the names against both and confirm the percentages (BO para 4.6.1). If the data differs from BRS, file a suspicious activity report with the FRC (para 4.8). BRS may also release a company's BO data to financial institutions on Form BOF6 (reg 14(1)(c)). See our beneficial ownership guide for Kenya.

What do banks commonly ask for beyond the law?

These items are bank practice, not law:

• Extra company papers. I&M's checklist for groups registered as a limited company (July 2025) lists CR1, CR2, CR12, a business licence and a company search alongside the incorporation documents, plus "World Check" reports on the entity and directors.
• Signatory photographs. The I&M and KCB group checklists ask for a photo of each signatory.
• Proof of address. For individuals, CBK lists a recent utility bill among the additional documents that can be used (CDD para 3.3.1).

Label these as bank policy on your form, so applicants know which items are yours rather than the regulator's.

The same sitting covers other duties: the CRS self-certification for new entity accounts (CRS Regulations reg 24(1)(a)(i)) and screening the company and its people before onboarding (CDD para 3.6.3.2; see sanctions and PEP screening in Kenya). Keep the file for at least seven years (POCAMLA s.46(4)). The POCAMLA and POTA guide covers the wider duties.

Where BAOS fits

BAOS, Creodata's Bank Account Opening System, is the account-opening workflow that sits beside your identity-verification provider and your core banking system.

• Entity types and templates. Fifteen business entity types, from sole proprietorships to SACCOs, NGOs and trusts. The Kenya corporate template collects the entity profile, directors, beneficial owners, signatories, the mandate and the board resolution.
• Checklist slots. Each document has a slot, with a slot per person for signatory and stakeholder documents. Staff verify documents one at a time or a whole application at once.
• Your own list. Your team changes the form without a software release, for example to ask for the new trust certificate. Kenyan ID and KRA PIN formats are checked as they are typed.
• Owners and screening. Beneficial owners are recorded with their ID and shareholding. BAOS lists every person who needs screening once each; the screening runs in your screening tool.
• AI pre-check (Enterprise). It reads seven Kenyan document types and cross-checks the name, registration number, KRA PIN and CR12 directors across them: an advisory pre-check, not a verification.

BAOS does not query BRS, KRA or IPRS, request BOF6 disclosures, apply the 10% test, rate risk or open the account: staff record the account number once your core banking system has opened it. Every workflow action is recorded with who, what role, when and from which address. Compare vendors with the account opening software buyer's guide for Kenya, or see BAOS in Kenya.

Frequently asked questions

What documents does a Kenyan bank need to open a limited company account?

Under reg 16(1): the certified certificate of incorporation or the memorandum and articles, the registered office, a certified board resolution naming the signatories, the particulars of the people who manage, control or own the company, financial statements, the company's KRA PIN and, where applicable, a previous bank's letter. POCAMLA adds the latest annual return, and CBK-licensed institutions also take the BRS official search (CR12) and BO form.

Is the CR12 still required?

We found no statute that requires a "CR12". Banks mean the BRS official search, which BRS calls "formerly CR12", and CBK's BO guidance (para 4.6.1) asks them to collect it and match beneficial owners against it. The statutory Form CR 12 is a notice of a company secretary's address.

Do we need a board resolution to open a company bank account in Kenya?

Yes. Reg 16(1)(d) requires a certified board resolution that authorises the account and names the signatories, and POCAMLA pairs it with the latest annual return. Each signatory then goes through full due diligence (reg 23).

What should a trust present now that the Trustees (Perpetual Succession) Act is repealed?

From 25 September 2026, written trusts register or incorporate under the Trust Administration Act 2026 with the Registrar of Trusts at BRS. Existing trusts have twenty-four months to comply, so expect older certificates during the transition, alongside the trust deed and the reg 18 particulars.

Can an NGO still open an account with its old NGO certificate?

The NGO Co-ordination Act was repealed when the PBO Act commenced on 14 May 2024. An NGO may present a PBO certificate or a certificate issued under the repealed Act, but the transition is contested, so confirm your approach with your supervisor.

To see a configurable Kenyan document checklist inside a staff-reviewed workflow, look at our account opening software for Kenyan banks or book a demo.