Insight type: Legal Alert

On 13 October 2025, the Government, through the Minister of Labour, Youth, Employment and Persons with Disability, published the Labour Institutions (Minimum Wage for Private Sector) Order, 2025 (the New Wage Order) through Government Notice No. 605A of 2025, revoking the Labour Institutions Minimum Wage Order, 2022 (the 2022 Wage Order).

The Virtual Asset Service Providers Act, 2025 (the Act) came into force following presidential assent on 15 October 2025, marking a crucial evolution in Kenya’s regulatory approach to virtual assets. The Act departs from the position established in 2015 by the Central Bank of Kenya (CBK) in its Banking Circular, which advised that virtual currencies were unregulated, not legal tender, and cautioned financial institutions against transacting with entities dealing in such currencies. 

At the just concluded Financial Action Task Force (FATF) Plenary meeting held between the 22 and 24 of October 2025, Nigeria, alongside other African nations Burkina Faso, Mozambique and South Africa was removed from the FATF Grey list- list of jurisdictions which had been placed under increased monitoring to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing (AML/CFT/CPF), and which had required an application of the prescribed risk-based approach in other nation’s financial and business dealings with Nigeria.

 

The African Growth and Opportunity Act (AGOA), a pivotal trade agreement between the United States and several sub-Saharan African nations, expired on 30 September 2025. Since its enactment in 2000, AGOA had been instrumental in strengthening United States/Africa economic ties by offering duty free access to the U.S. market for over 1,800 products from eligible African countries (in addition to more than 5,000 products previously listed under the U.S. Generalised System of Preferences, a separate and long-standing U.S. trade program that itself expired at the end of 2020).

The expiry of AGOA raises questions about the future of trade between the U.S. and East Africa, particularly for key regional players like Kenya and Tanzania. Unless AGOA is reinstated or replaced with an analogous arrangement soon, the effects of this change will likely be felt across various sectors, necessitating a strategic recalibration for these countries and their respective industries.

The Nigerian Communications Commission (NCC) has issued Draft Regulatory Guidelines for the use of the lower 6 GHz (5925–6425 MHz) Band (the Guideline). The Guideline’s main proposition is to establish a framework for accessing and utilising this frequency range to support high-bandwidth, high-speed, and low-latency applications such as Wireless Access Systems (WAS) and Radio Local Area Networks (RLAN) for Wi-Fi 6 applications. The Guideline covers entities involved in the development, production, importation, sale, and use of WAS operating on this band.

 

The High Court of Kenya recently held that property valuers owe their clients a duty of care, and if such a duty is breached through inaccurate valuation, they will be held liable to compensate their clients for losses arising from such negligence. The High Court nonetheless observed that parties relying on a valuer’s report must also conduct their own due diligence on the property to mitigate potential losses.

The UAE is a complex but increasingly important jurisdiction for cross-border enforcement. It combines an onshore Islamic civil law system conducted in Arabic with offshore English-language common law courts in the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market. The interaction between these distinct legal systems makes enforcement challenging, demanding specialist expertise and careful strategy. At the same time, the overlap between these systems provides creditors with a wider range of options to obtain freezing orders and pursue enforcement in support of domestic, foreign, or arbitral proceedings.

The Parliament of Uganda enacted the Technical and Vocational Education and Training Act, 2025 (Act No. 3 of 2025), which came into force on 15th March 2025. This legislation consolidates and replaces previous laws governing technical and vocational education and training (TVET) providers, including the repeal of the Business, Technical, Vocational Education and Training Act.

The Finance Act, 2025, effective 1 July 2025, has fundamentally reshaped Kenya’s import ecosystem by amending Section 44A of the Tax Procedures Act, 2015. This mandates a valid Certificate of Origin (CoO) for every import, irrespective of origin or trade agreement status, positioning it as a non-negotiable requirement to be enforced by the Kenya Revenue Authority (KRA).

Nigeria’s insurance sector has been considered underdeveloped relative to the size of the economy. Persistent issues such as low penetration, weak public confidence and undercapitalisation have hindered its ability to deliver effective financial intermediation and risk protection. Previous reform attempts, ranging from revised capital thresholds to piecemeal legislative updates, sought to address these challenges but stopped short of achieving a comprehensive transformation.