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Kenya's CII Regulations

Computer Misuse and Cybercrime (Critical Information Infrastructure and Cybercrime Management) Regulations, Legal Notice 44 of 2024. In force since 9 February 2024.

The Regulatory Framework

Kenya's CII Regulations establish mandatory cybersecurity obligations for operators of Critical Information Infrastructure — infrastructure whose disruption would have a significant impact on public health, safety, the economy, or national security.

Governing Act

Computer Misuse and Cybercrimes Act 2018 (Cap. 79C)

Operative Regulations

Legal Notice 44 of 2024, commenced 9 February 2024

Enforcement Authority

Director, National Computer and Cybercrimes Co-ordination Committee (NC4)

CII Designation

16 sectors formally designated, including Energy, Water, Transport, Financial Services, ICT

Compliance Timeline

Key deadlines from the date of commencement — 9 February 2024. Most obligations are already due.

9 Feb 2024 Commencement
Day Zero

Regulations enter into force

All mandatory obligations under Legal Notice 44 of 2024 take effect. Designated CII owners are immediately bound by the access control, data localisation, outsourcing notification, and incident reporting requirements.

Aug 2024 6 months
Overdue

Organisational policies, procedures and codes of practice (Regulation 34)

CII owners were required to formulate, review and update organisational policies, procedures and codes of practice to ensure the protection, preservation and management of their CII. This deadline has passed. Most operators are in breach.

Feb 2025 12 months
Overdue

Annual cybersecurity risk assessment (Regulation 17)

The first annual mandatory cyber-risk assessment was due within 12 months of commencement. The Director may issue directives requiring designated CII owners to conduct this assessment. The obligation now recurs annually.

Ongoing Continuous
Active Now

Incident reporting, access controls, data localisation, audits

24-hour incident reporting to Sectoral COC, CISO designation, security logging and monitoring, penetration testing, annual internal audits, risk register maintenance, and disaster recovery planning are all continuous ongoing obligations.

Mandatory Obligations

What the Regulations require of designated CII owners, organised by category.

Reg 32 · 33

CISO Designation

Every designated CII owner must appoint a Chief Information Security Officer. The CISO must be a Kenyan citizen, hold a master's degree in information security or a related field, and have at least five years of demonstrable professional experience in CII protection. Multiple CII owners may jointly appoint a single CISO.

Reg 17 · 31(2)(j) · 31(2)(l)

Annual Risk Assessment & Risk Register

Annual cybersecurity risk assessment to identify existing vulnerabilities is mandatory. Results must be maintained in a live cybersecurity risk register that catalogues and profiles the information and cyber risks to the CII.

Reg 31(2)(k)

Annual Internal Cybersecurity Audit

CII owners must conduct annual internal cybersecurity audits to check compliance with the directives issued under Regulation 20. These complement the external NC4 audit regime and feed into the compliance report.

Reg 65(c)

24-Hour Incident Reporting

All cybersecurity incidents must be reported to the relevant Sectoral Cybersecurity Operations Centre within 24 hours of becoming aware. Using Form CMCA 7, which requires incident classification, impact details, response steps taken, and third parties informed.

Reg 28

Data Localisation

CII and the critical information it contains must be domiciled and located in Kenya. Any intention to store critical information outside Kenya requires a formal application to and approval from the Committee, in consultation with the National Security Council.

Reg 34

Mandatory Policies (Deadline Passed)

Organisational policies, procedures and codes of practice must be formulated and reviewed annually. Must specify storage and archiving procedures, modalities for sharing CII within the organisation and with third parties, and data lifecycle management procedures.

Reg 39(d)

Penetration Testing

Regulation 39(d) requires CII owners to adopt procedures for conducting regular security audits and penetration testing to identify vulnerabilities and system weaknesses. This is an explicitly named mandatory measure for virtual access to CII — not a recommendation.

Reg 42

Disaster Recovery Site

CII owners must establish a disaster recovery and backup site that is geographically distinct from the primary CII location. The backup site must support full data retrieval and system restoration. Routine periodic backup procedures are required.

Reg 31(2)(a) · 31(2)(d)

Asset Classification & Personnel Vetting

Identification, classification and cataloguing of all CII assets is a baseline security requirement. Background checks on all personnel handling CII information or data are also mandatory — covering employees, contractors, and service providers.

Reg 30 · 31(2)(m)

Awareness & Exercises

A cybersecurity awareness programme covering IR, insider threats, risk assessment, and emerging technologies must be implemented. CII owners must also participate in cybersecurity exercises and drills in collaboration with the Committee and other CII sectors.

Reg 71(3)

Best Practice Standards Adoption

Owners of critical information infrastructure may on their own initiative identify, evaluate and adopt global best practices and operational standards on cybersecurity. IEC 62443 is the recognised international best practice for OT/ICS security — the appropriate standard for energy, water, and transport CII.

Reg 13

Outsourcing Notification

Where any capability relating to the management or operation of CII is outsourced, the owner must notify the Committee and enter written agreements with the service provider. The service provider must comply with the same security standards as the CII owner.

What NC4 Audits Examine

NC4 auditors follow Form CMCA 6 — the prescribed audit report template under Regulation 49. Compliance and risk-based approaches are both used (Regulation 48). Auditors may enter premises with 30-day notice and require the production of any documents.

Audit Domain What Is Assessed
Network Security Firewall configuration and rules; intrusion detection and prevention systems (IDPS); network access control; wireless network security; VLAN segmentation
System Security Operating system patching and updates; antivirus and endpoint security; secure configuration of servers and endpoints; access control to critical systems
Data Security Data classification and handling procedures; encryption at rest and in transit; backup and disaster recovery procedures and testing
Application Security Secure coding practices; web application security; application authentication and authorisation
Physical Security Access control to data centres and server rooms; surveillance and monitoring; visitor management and access registers
Risk Assessment Identified risks; risk analysis and posture; risk mitigation recommendations; adequacy of established controls
Compliance Assessment Regulatory compliance against the Act and Regulations; industry standards (ISO 27001, NIST, etc.)

The audit template does not explicitly list IEC 62443. For OT-heavy CII — energy, water, transport — this is the appropriate standard. We map your OT environment to IEC 62443 and prepare you for audit on the domains that matter most to your infrastructure.

Designated CII Sectors

The Second Schedule to the Regulations lists the critical sectors. Formal designation of specific infrastructure was published in the Kenya Gazette on 31 January 2022.

Sector Critical Services
Energy Electricity generation (all forms), transmission/distribution, electricity market, petroleum extraction/refinement/transport/storage, natural gas extraction/distribution/storage
ICT Web services, data centre/cloud services, software as a service, voice/data communications, internet connectivity
Water Drinking water storage, distribution and quality assurance; wastewater collection and treatment
Financial Services Banking, payment transactions (including mobile money and settlement systems), stock exchange
Transport Air navigation services, airports, road transport, public railway management, railway transport services, maritime and shipping management, docking, postal/shipping
Health Emergency healthcare, hospital care (inpatient and outpatient), supply of pharmaceuticals, vaccines, blood and medical supplies, infection/epidemic control
Industry Critical industry employment systems; chemical/nuclear industry hazardous materials storage/disposal and safety of high-risk industrial units
Other Sectors Food (agriculture, supply, distribution, quality/safety), Space, Environment, Public Order and Safety, Civil Protection, Civil Administration, Education, Election, Defense

Understand Where You Stand

Not sure which obligations apply to your organisation, or how far behind you are? We start with a structured compliance gap mapping — identifying what the regulations require, what you have, and what needs to be done.

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