Nairobi · KenyaResearch · Training · Consultancy+254 734 890 895info@policy.co.ke
  1. Home
  2. Sectors
  3. Public Finance and Revenue

Sector consultancy

Public Finance and Revenue

Kenya's public finances are being tightened from every side: a debt anchor in law, compliance-led Finance Acts, a new formula for sharing revenue among counties, and digital systems that bring county revenue and spending under closer oversight. Policy Oracle brings revenue, expenditure and value-for-money analysis to the institutions making these decisions.

The policy environment

Public finance in Kenya runs on Chapter Twelve of the Constitution and the Public Finance Management Act, 2012, which assign the National Treasury, county treasuries and accounting officers their duties and set the budget calendar for both levels of government. Each year the Division of Revenue Act splits shareable revenue between the national and county governments, and the County Allocation of Revenue Act divides the county share among the 47 counties. For 2026/27 the Division of Revenue Act, 2026 set the county equitable share at Sh428 billion after seven mediation sessions between the two Houses. The Controller of Budget authorises withdrawals, the Auditor-General audits public accounts and the Commission on Revenue Allocation recommends the basis for sharing revenue.

Horizontal sharing now follows the Fourth Basis, recommended by the Commission on Revenue Allocation and approved by Parliament in 2025 for the five financial years from 2025/26 to 2029/30. It protects each county's baseline, adds an affirmative allocation for 12 historically marginalised counties and distributes the balance by indices including population, poverty and geographical size. Own-source revenue remains the weak link: the Controller of Budget reports manual collection, outdated valuation rolls and weak enforcement. In July 2026 the Commission gazetted Standards and Guidelines on the Automation of County Own Source Revenue, while the National Treasury has advanced its own Integrated County Revenue Management System, which the Council of Governors opposes as dictating the systems counties must use.

At the national level, the Public Finance Management (Amendment) Act, 2023 replaced the nominal debt ceiling with an anchor of 55 per cent of GDP in present value terms, and the Medium Term Revenue Strategy, now in its final year, steers tax policy towards a broader base. The Finance Act, 2026, assented on 23 June 2026, leans on compliance: a tax amnesty, wider Kenya Revenue Authority powers against avoidance and prepopulated returns. Spending controls are going digital: the electronic Government Procurement system became mandatory from July 2025, and the Treasury has ordered counties to integrate it with the Integrated Financial Management Information System. The 2025 Open Budget Survey still finds no formal public participation in budget implementation or audit.

Where the pressure is

The decisions in front of Kenyan institutions now.

Reviewed October 2026. Each pressure traces to a law, a policy or a ruling set out below.

01

Meeting the debt anchor without stalling services

The 2023 amendment gives the National Treasury five years to bring public debt within the 55 per cent of GDP threshold, narrowing room for new spending through 2028. Ministries and counties must show value for money to defend their allocations in a consolidating budget.

02

Revenue sharing under strain

The 2026/27 county share was settled only after seven mediation sessions, with the Senate seeking more than Sh450 billion and the National Assembly proposing Sh420 billion. Counties need evidence on the cost of devolved functions, including those still being transferred, to argue their case under the Fourth Basis.

03

Own-source revenue automation and control

The Commission on Revenue Allocation's 2026 standards set a compliance clock, with quarterly reporting and a 90-day remediation window, while the Treasury's integrated system remains contested by governors. Counties must decide how to modernise collection, keep ownership of their data and close the leakages the Controller of Budget has documented.

04

e-procurement integration and cash discipline

Counties faced a Treasury deadline of September 2026 to integrate e-GP with IFMIS, and the Controller of Budget now sees every county bank account. Executives and assemblies need procurement and cash management processes that hold up under real-time scrutiny.

05

Compliance-led tax policy

The Finance Act, 2026 favours enforcement over new rates: an amnesty on penalties and interest where principal is paid by 31 December 2026, withholding tax on payment and digital platform charges, and expanded anti-avoidance powers. Businesses and public bodies need fiscal impact analysis of what these changes raise and whom they burden.

06

Budget transparency and participation gaps

The 2025 Open Budget Survey scores Kenya 56 out of 100 on transparency, below the threshold for sufficient disclosure, and found no Mid-Year Review for 2023/24 and no formal public role in budget implementation or audit. National and county budget offices face pressure to publish more and to open execution to citizen monitoring.

Laws, plans and institutions

The framework that governs the sector.

The Acts and regulations that create obligations, the policies and programmes that set direction, and the institutions that hold the mandate.

Acts and regulations

Public Finance Management Act, 2012
Governs the management of public money at both levels of government: budget preparation and approval, county treasuries, accounting officers, borrowing and reporting. It is the reference standard for any public expenditure or PFM review.
Public Finance Management (Amendment) Act, 2023
Replaced the Sh10 trillion nominal ceiling with a debt anchor of 55 per cent of GDP in present value terms, with a temporary excess of not more than five per cent permitted in exceptional circumstances. It requires the National Treasury to bring debt within the threshold over five years, which shapes fiscal consolidation through 2028.
County Public Finance Laws (Amendment) Act, 2025
Assented on 13 August 2025, it harmonises county budget timelines with the national calendar, strengthens county assembly oversight and gives the Controller of Budget viewer access to all county bank accounts. It responds to the proliferation of county commercial bank accounts questioned by the Controller of Budget and the Auditor-General.
Division of Revenue Act, 2026 and County Allocation of Revenue Act, 2026
The Division of Revenue Act, 2026, assented on 15 June 2026, sets the county equitable share for 2026/27 at Sh428 billion and protects county allocations from cuts caused by national revenue shortfalls. The County Allocation of Revenue Act, 2026, assented on 29 June 2026, divides that share among the counties under the Fourth Basis and sets ceilings on county recurrent spending.
Finance Act, 2025 and Finance Act, 2026
The annual Finance Acts amend the tax statutes to give effect to the budget; the Finance Act, 2025 took effect on 1 July 2025. The Finance Act, 2026, assented on 23 June 2026, pairs a tax amnesty on penalties and interest with wider withholding tax, new excise measures and stronger anti-avoidance powers.
Tax Procedures Act, 2015
Harmonises the procedures for administering tax laws, from registration and returns to assessments, objections, penalties and amnesties. The 2026 amendments introduce prepopulated returns, allow the Kenya Revenue Authority to recover unpaid levies and fees as taxes and broaden its power to assess tax avoidance.
Public Procurement and Asset Disposal Act, 2015
Governs procurement and asset disposal by national and county public entities, and sets the rules the e-GP system now applies electronically. In July 2026 the President returned the Public Procurement and Asset Disposal (Amendment) Bill, 2024 to Parliament with reservations over its definition of local and foreign firms.

Policies, strategies and programmes

The Medium Term Revenue Strategy (An Approach for Enhancing Domestic Revenue) FY 2024/25-2026/27
The National Treasury's framework for raising domestic revenue through coordinated tax policy and administration reforms, including a review of exemptions and reliefs. The 2026/27 financial year is its final year.
National Policy to Support Enhancement of County Governments' Own-Source Revenue, 2019
Sets the national framework for strengthening county revenue legislation, administration and systems, and is the policy basis for the Treasury's Integrated County Revenue Management System. County revenue strategies should align with it.
Fourth Basis for Sharing Revenue among Counties, 2025/26-2029/30
The Commission on Revenue Allocation's formula, approved by the Senate and the National Assembly in 2025. It guarantees each county's baseline, distributes additional revenue by indices including population, poverty and geographical size, and provides an affirmative allocation for 12 marginalised counties.
Commission on Revenue Allocation Standards and Guidelines on the Automation of County Own Source Revenue, 2026
Gazetted on 27 July 2026 under Article 216 of the Constitution, they require county revenue governance committees, county ownership of systems and data, vendor exit protections, mapping to the Standard Chart of Accounts and quarterly compliance reporting. Non-compliant counties face a 90-day remediation period.
Electronic Government Procurement (e-GP) and IFMIS
The e-GP platform digitises procurement from planning to payment and became mandatory for public entities from 1 July 2025, with supplier registration a precondition for bidding. The Treasury directed all 47 counties to complete its integration with the Integrated Financial Management Information System by the end of September 2026.

Institutions

The National Treasury and Economic Planning
Leads fiscal policy, the budget, public debt management and the government's financial systems, including IFMIS, e-GP and the proposed county revenue system. It prepares the Division of Revenue Bill and the Finance Bill each year.
Commission on Revenue Allocation
Recommends the basis for sharing revenue between and among the national and county governments under Articles 215 and 216 of the Constitution, and advises on strengthening county revenue. Its 2026 automation standards give it a direct role in county revenue systems.
Office of the Controller of Budget
Authorises withdrawals from public funds and reports on budget implementation at both levels of government under Article 228. Since the 2025 amendments it has viewer access to all county bank accounts.
Office of the Auditor-General
Audits the accounts of the national and county governments and other public entities under Article 229, and its reports drive parliamentary and county assembly accountability. The 2025 Open Budget Survey rates its oversight as adequate.
Kenya Revenue Authority
Administers national taxes under the Tax Procedures Act, 2015 and may be appointed as a county revenue collection agent under the Public Finance Management Act, 2012. The Finance Act, 2026 expands its powers on avoidance and on recovery of levies and fees.
Parliamentary Budget Office
Provides budget and fiscal analysis to Parliament. The 2025 Open Budget Survey notes that its independence is not fully guaranteed in law and that it lacks sufficient staff and resources.
Intergovernmental Budget and Economic Council
The forum under the Public Finance Management Act, 2012 where the national and county governments consult on budget, revenue and economic matters. It has hosted the talks on the rollout of the integrated county revenue system.

Who does what

Two levels of government, one sector.

How the Fourth Schedule of the Constitution of Kenya, 2010 divides the sector between the national government and the 47 county governments.

National government

  • National economic policy and planning
  • Monetary policy, currency, banking and the regulation of financial institutions
  • Public investment
  • National statistics and data on population, the economy and society
  • Capacity building and technical assistance to the counties
  • Income tax, value added tax, customs and excise duties (Article 209)

County governments

  • Trade development and regulation, including markets and trade licences
  • Liquor licensing, betting, casinos and public entertainment
  • Traffic and parking within county transport
  • Control of outdoor advertising
  • County planning and development, including land survey and mapping
  • Property rates and entertainment taxes (Article 209)

What we offer

Consultancy built on the policy environment.

Our practices combine to answer the questions this sector raises. Every assignment is scoped to the institution.

  1. Own-source revenue mobilisation strategies

    We assess revenue potential, legislation, tariffs, collection systems and enforcement stream by stream, and design strategies aligned with the National Policy to Support Enhancement of County Governments' Own-Source Revenue, 2019 and the Commission on Revenue Allocation's 2026 automation standards. The service builds on our County Fiscal Devolution Review and Revenue Mobilisation Strategy for Machakos County Government (2021).

  2. Public expenditure and PFM reviews

    We review budget credibility, execution, pending bills, cash management and procurement against the Public Finance Management Act, 2012 and the County Public Finance Laws (Amendment) Act, 2025. Findings are ranked by fiscal impact so that accounting officers and assemblies know which reforms to make first.

  3. Cost-benefit and value-for-money analysis

    We build cost-benefit, cost-effectiveness and business case models that test whether programmes justify their cost and how they should be financed. Recent work includes the county service efficiency and cost-benefit analysis for the Consortium of County Governments (2024) and the cancer screening programme economic and business case for the National Cancer Institute (2023).

  4. Fiscal impact and budget analysis

    We estimate the revenue, distributional and sector effects of Finance Acts, revenue-sharing decisions and county finance laws before and after enactment. Clients receive analysis they can use in submissions to Parliament, county assemblies and the National Treasury.

  5. Health and sector financing analysis

    We analyse how sectors are financed across the two levels of government, including transfers, pooled funds and own-source revenue, and what that spending delivers. Our 2025 economic analysis of devolved health financing and service delivery for the National Syndemic Diseases Control Council applies this method.

Our work in this sector

Delivered for Kenyan institutions.

YearClientEngagementPractice
2025National Syndemic Diseases Control CouncilEconomic Analysis of Devolved Health Financing and Service DeliveryHealth Financing
2024Consortium of County GovernmentsCounty Service Efficiency and Cost-Benefit AnalysisPublic Finance / CBA
2023Ministry of Devolution and ASALsNational Economic Analysis of Devolution OutcomesDevolution Economics
2022County Government of MakueniSub-County Economic Development and Devolution Impact AssessmentDevolution Economics
2021Machakos County GovernmentCounty Fiscal Devolution Review and Revenue Mobilisation StrategyPublic Finance

Public Finance and Revenue

Tell us the decision you are facing.

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.

Your enquiry goes straight to our team at info@policy.co.ke, and we reply within one working day. We use your details only to respond.

WhatsApp