Sector consultancy
Kenya's climate framework now carries binding obligations: carbon trading rules, county climate funds, a new disaster risk law and climate disclosure for public interest entities from 2027. Policy Oracle helps governments, programmes and companies meet them with evidence that stands up to scrutiny.
The policy environment
The Climate Change Act, 2016 is the spine of the framework. It gives the National Climate Change Council, chaired by the President, oversight of national climate action, makes the Climate Change Directorate the lead technical agency and coordinator of measurement, reporting and verification, and requires every county to mainstream climate action into its County Integrated Development Plan. The Climate Change (Amendment) Act, 2023 added a full carbon markets regime: community development agreements, minimum community shares of project earnings, a National Carbon Registry and offences for unauthorised trading. The Environmental Management and Co-ordination Act, 1999 and the Energy Act, 2019 carry the environmental licensing and energy planning duties that sit alongside it, with NEMA and EPRA as the regulators.
The past eighteen months have moved the framework from paper to practice. Kenya submitted its Second Nationally Determined Contribution in April 2025, committing to a 35 per cent cut in emissions below business as usual by 2035, most of it conditional on international support. The Climate Change (Non-Market Approaches) Regulations, 2026 created an approval route for adaptation and resilience projects that do not trade credits, and the Kenya National Carbon Registry was launched in February 2026. The National Disaster Risk Management Act, 2026 established a National Disaster Risk Management Authority and county committees, and the National Treasury launched the Disaster Risk Financing Strategy 2026-2030 in June 2026.
Money and disclosure are where the framework now bites. Under the Financing Locally-Led Climate Action (FLLoCA) Programme all 47 counties have passed climate change fund laws, completed participatory climate risk assessments and adopted County Climate Change Action Plans, and counties commit a share of their development budgets to climate action. The programme's first phase is in its final grant cycle, so counties must now sustain these systems from their own budgets and new sources. In the financial sector, the Central Bank of Kenya issued the Kenyan Green Finance Taxonomy and a Climate Risk Disclosure Framework for banks in April 2025, and ICPAK's adoption of IFRS S1 and S2 makes sustainability disclosure mandatory for public interest entities for periods beginning on or after 1 January 2027.
Where the pressure is
Reviewed October 2026. Each pressure traces to a law, a policy or a ruling set out below.
FLLoCA's first phase is paying its final cycle of county climate resilience investment grants, and counties must decide how to keep their climate change units, ward planning committees and funds running. The quality of their action plans, budget commitments and evidence of results will decide which counties attract the next phase and other climate finance.
The two-year transition the 2024 Regulations allowed existing projects has run its course, and every project now needs approval, a registry record and, on public or community land, a community development agreement. The January 2026 closure of clean cooking company KOKO Networks, reported to follow the withholding of a government letter of authorisation, showed what authorisation decisions mean for investors, households and the credibility of Kenyan credits.
The Second NDC and the Paris Agreement's Enhanced Transparency Framework require evidence that mitigation and adaptation actions deliver. The UNFCCC technical review of Kenya's first Biennial Transparency Report in 2025 found that a system to track NDC implementation is still needed and that the adaptation MRV system is only partly operational.
The National Treasury now has a climate code in the budget classification and a tagging system for disaster risk reduction and climate adaptation spending. The tags are useful only if ministries and counties apply them consistently, which requires classification rules, training and checks that link tagged spending to the NCCAP and county action plans.
Public interest entities, including listed companies, banks and insurers, must report under IFRS S1 and S2 for periods beginning on or after 1 January 2027, while banks are adopting the CBK Climate Risk Disclosure Framework and Green Finance Taxonomy. Boards need scenario analysis, emissions data and governance evidence that will survive audit and supervisory review.
The National Disaster Risk Management Act, 2026 requires a new Authority, County Disaster Risk Management Committees and disaster plans, and the Disaster Risk Financing Strategy 2026-2030 asks both levels of government to fund risk reduction before disasters strike. Counties must align their own disaster laws, contingency plans and budgets with the new framework.
Laws, plans and institutions
The Acts and regulations that create obligations, the policies and programmes that set direction, and the institutions that hold the mandate.
Who does what
How the Fourth Schedule of the Constitution of Kenya, 2010 divides the sector between the national government and the 47 county governments.
What we offer
Each service has a defined scope, method, timeline and set of deliverables, and can be tailored to your institution.
Participatory climate risk assessments and County Climate Change Action Plans that meet FLLoCA standards and translate into fundable ward and county investments.
See the serviceClassification rules, tagging and expenditure reviews that show what national and county budgets spend on climate adaptation, mitigation and disaster risk.
See the serviceLegal, institutional and community readiness for carbon projects under the Climate Change Act and the 2024 Carbon Markets Regulations, including fair benefit-sharing arrangements.
See the serviceMeasurement, reporting and verification systems that track mitigation and adaptation results for ministries, counties and programmes, and stand up to independent review.
See the serviceClimate risk assessment, taxonomy alignment and IFRS S2-aligned disclosure for banks, insurers and companies facing CBK guidance and ICPAK's 2027 mandatory reporting.
See the serviceOur work in this sector
| Year | Client | Engagement | Practice |
|---|---|---|---|
| 2023 | Dorcas Aid International | Community Resilience M&E and Indicator Verification | Resilience M&E |
| 2023 | Machakos County Government | County Climate-Resilient Agriculture M&E System | Agriculture M&E |
Key references
Policy environment reviewed October 2026. Laws, regulations and programmes change; consult the official text before relying on any summary here.
Climate Change and Environment
Tell us what you need to decide and by when. We will set it against the law, policy and budget realities of the sector and propose the work.