Chama Account Opening Requirements in Kenya: Officials, Minutes, Mandates and KYC

Short answer: We found no Kenyan account-opening rule written for chamas. Banks identify the officials and signatories as individuals, and commonly ask for the group's constitution, minutes or a resolution naming the signatories, each signatory's ID and often their KRA PIN, and a registration certificate where the group has one. SACCOs follow SASRA's guideline, which names the certificate of registration and the officials' identities.

This guide is for branch, operations and compliance teams at Kenyan banks, microfinance banks and SACCOs that open accounts for chamas, welfare groups and table-banking groups, and for product owners designing a group journey. 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 say about opening a chama account?

Less than most checklists suggest. POCAMLA lists the official records for an individual and for a body corporate (s.45(1A)(a) and (b)), and an unregistered chama is neither. We found no regulation in the POCAML Regulations 2023 that covers unincorporated associations, clubs, groups or chamas.

That does not leave the account outside due diligence:

• Due diligence still applies. CBK's CDD guidance applies to every relationship, whatever the amount (para 3.2), and anonymous or fictitious accounts are banned (reg 13(1); CDD para 5.4).
• The officials are persons acting for the customer. The bank verifies that each is authorised, then identifies and verifies them (s.45(3); reg 23). CBK expects documentary proof of authority, full due diligence on each authorised person, and a check of legal capacity (CDD para 3.4.2).
• Each official needs an official record. Any one of a birth certificate, national ID card, passport or driver's licence is enough (s.45(1A)(a)).
• Guidance fills the gap. CBK's CDD guidance says legal persons can include associations (para 1.4.7). Its BO guidance tells banks to look at the office bearers of clubs and societies (president, secretary, treasurer and committee), senior management and other members with effective control (para 4.4). The source documents it names include the certificate of registration, the constitution or rules, meeting minutes and the list of committee members.

SACCOs have a written rule. SASRA's guideline SASRA/GG/1/2024 (§6.1.1(1)(c)) asks unincorporated entities for the certificate of registration, evidence of the registered address where applicable, and the identities of the officials or signatories. Identity is verified through a reliable, independent source, such as IPRS or the KRA tax database (§6.1.1(2)), and anyone representing a member must be authorised in writing (§6.1.2). Our guide to SACCO member onboarding under SASRA covers the rest, and AML software for SACCOs the screening side.

Does a chama have to be registered to open a bank account?

We found no Kenyan law that says an unregistered group cannot bank, and at least one bank, I&M, publishes requirements for unregistered informal groups. Registration matters because it decides which certificate the group can show you. There are three routes, and none is settled for chamas.

The Community Groups Registration Act and the September 2026 ruling

The Community Groups Registration Act (Cap. 108A) has been in force since 26 July 2022. Its main points:

• What it covers. A community group is a voluntary, self-organised association of people from the same community with a common purpose; PBOs, NGOs and political groups are excluded (s.2).
• Who registers groups. The Director of Social Development, a national office, with a county co-ordinator in each county (ss.3(2)(b), 4). A group needs at least ten members, or five for a special interest group, and files its constitution with the application (ss.9(2), 10).
• The certificate. The 2026 Regulations (LN 154 of 2026) provide for a "Certificate of Registration for Community Group" in Form 2. It shows the group's name, type, registration number, county, sub-county and ward, and date of registration.
• Renewal. Registration is valid for two years and then renewed annually (reg 18; s.14(1)).
• Older registrations. Groups registered by the national government before the Act are deemed registered under it (s.41). We found no rule on how older social-services certificates are treated after the Act's one-year compliance window.

On 10 September 2026 the High Court (Mathare Social Justice Centre & another v Bore, Cabinet Secretary for Labour & Social Protection & 8 others, [2026] KEHC 13419 (KLR)) declared the Act unconstitutional because it was passed without sufficient public participation. It suspended the declaration for six months: unless the defect is cured, it takes full effect at midnight on 10 February 2027. As of 8 October 2026 we found no appeal, stay or amending Bill. Do not build your chama policy on the assumption that this Act is the long-term regime.

The Societies Act and company routes

Under the Societies Act (Cap. 108), a "society" includes "any club, company, partnership or other association of ten or more persons", excluding registered companies and statutory corporations (s.2). The Registrar issues a certificate of registration or exemption (s.10(3)). We found no primary text on which regime a chama should use. Some groups incorporate as companies instead; the company documents then apply, as set out in our corporate account opening requirements.

In practice: accept the certificate the group actually holds (or none, if your policy allows informal groups), record which route it came from, note the renewal date on a Form 2 certificate, and plan for February 2027.

Does a chama need its own KRA PIN?

Unclear in law. The Tax Procedures Act lists opening an account with a financial institution as a transaction that needs a PIN (First Schedule item (11)), but we found nothing in the text on how that applies to an unincorporated group. KCB's Tuungane page (read 8 October 2026) states that no group KRA PIN is required, while I&M asks for each signatory's PIN. Confirm your approach with your supervisor; our guide to IPRS and KRA PIN checks covers the signatories' side.

What do banks commonly ask a chama for?

These are bank practice, not law, and they differ:

A dash means the item was not on the list we read. For unregistered informal groups, I&M asks only for a photo, ID or passport and KRA PIN for each signatory. Groups registered as a company give I&M the full company pack. Write your own list, and label each item as bank policy so a group's secretary knows what is yours rather than the regulator's.

Officials, minutes and mandates: what should the record show?

A defensible chama file answers four questions.

1. Who are the officials? Name, office (chair, secretary, treasurer or committee member), ID type and number, and the date they took office. Each official and signatory goes through individual due diligence (reg 23; CDD para 3.4.2).
2. What did the group decide? The minutes or resolution that authorise the account and name the signatories, with the meeting date and who signed the minutes. For a board resolution, the company's articles set the rules; for a chama, the group's constitution does.
3. How is the account operated? The mandate, for example "any two of the three officials, one of them the treasurer". This comes from the group's constitution and your form, not from statute; see authorised signatories and signing mandates.
4. Who are the members? We found no rule that every member of a group must be identified. CBK points to office bearers and members with effective control (BO para 4.4), and KCB asks for the list of members. Whether you identify and screen every member is a risk-based decision for your policy; confirm it with your supervisor. Screening of those you do list follows sanctions and PEP screening in Kenya.

How should a change of officials be handled?

Chama officials change when the group holds elections. Treat each change as a change in the persons acting for the customer:

• Fresh authority. Take new minutes or a new resolution naming the incoming signatories, and run full due diligence on each new official (reg 23; CDD para 3.4.2).
• A review trigger. CBK gives a new signatory or a change of beneficial owner as an example of an event that should trigger a review of the customer's records (CDD para 3.6.1).
• The group's own duties. For groups registered under the Community Groups Act, a change in "the banking arrangements of a community group" is a material change (reg 24(2)(d)) that the group must notify within fourteen days (reg 24(3)). A suspended group may not withdraw from its bank account without the Director's approval (reg 20(2)(a)). These duties fall on the group, not the bank, while the Act remains in force.
• Records. Keep the old mandate and minutes with the new ones: CDD records are kept for at least seven years after the relationship ends (POCAMLA s.46(4)).

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. For chamas:

• A group applicant kind. Group (chama) accounts have their own form, with nine group types and a Kenya chama starter template. It ships as a draft that your team reviews and publishes.
• The group's people. A member register added row by row, the elected officials, and the group meeting resolution, all on the same record.
• Documents. An eight-document starter pack for chamas, with slots per member and per signatory. Your team sets the documents it accepts (a Form 2 certificate, a Societies Act certificate, or none for informal groups) in the form builder, without a software release.
• Capture. Applicants apply online or staff capture the application for them. Drafts autosave, which matters when a register is completed over several meetings. Forms can carry English and Swahili, and Kenyan ID and KRA PIN formats are checked as they are typed.
• Screening list. BAOS lists every member, official and signatory who needs screening once each, even when one person holds two roles. The screening runs in your screening tool.
• Review. Reviewers claim the application, verify documents, and approve or reject it, or email the applicant for more information. Staff then record the account number once the core banking system opens the account.

BAOS does not check IDs against IPRS or KRA, screen against lists, rate risk or send SMS. It also does not invite each member to fill in their own details: one person, or a staff member, enters the register. See BAOS in Kenya for the Kenya templates, and the account opening software buyer's guide for Kenya for vendor-neutral criteria.

Frequently asked questions

Does a chama have to be registered before it can open a bank account in Kenya?

We found no Kenyan law that bars an unregistered group from banking, and I&M publishes requirements for informal groups. Registered groups show a certificate under the Community Groups Registration Act or the Societies Act, or company documents if they have incorporated. Each bank sets its own policy.

What documents do banks ask a chama for?

Commonly the registration certificate where there is one, the constitution, minutes or a resolution naming the signatories and the mandate, and an ID, photo and often a KRA PIN for each signatory. KCB also asks for the list of members and a year's accounts for older groups. These are bank requirements, not statutory ones.

Does a chama need its own KRA PIN?

The Tax Procedures Act lists opening an account as a transaction that needs a PIN, but we found nothing in it on how that applies to an unincorporated group. KCB states that no group KRA PIN is required for its chama account. Confirm your approach with your supervisor.

What does the High Court ruling on the Community Groups Registration Act mean for banks?

On 10 September 2026 the High Court declared the Act unconstitutional and suspended the declaration until midnight on 10 February 2027. Unless the defect is cured by then, the declaration takes full effect. We found no appeal, stay or amending Bill as of 8 October 2026. Keep your chama policy flexible, and confirm with your supervisor how to treat Form 2 certificates nearer the date.

What does a SACCO need from a group that joins as a member?

SASRA/GG/1/2024 §6.1.1(1)(c) asks for the certificate of registration, evidence of the registered address where applicable, and the identities of the officials or signatories. Anyone acting for the group must be authorised in writing (§6.1.2).

To see a chama onboarded with its register, officials and resolution on one record, explore our account opening software for Kenyan banks and SACCOs or book a demo.