Patrick Njoroge says M-Pesa and Airtel Money should pay users interest on wallets

The former CBK governor wants trust income shared with wallet holders. The draft Bill keeps the charity rule and leaves room for another use.

Former Central Bank of Kenya governor Patrick Njoroge wants M-Pesa and Airtel Money customers to receive a share of the income their wallet balances earn. In comments submitted on September 28 on the government's draft National Payment System Policy, Njoroge, who led CBK from 2015 to 2023, asked for the payment laws to require regular "bonus payouts" to wallet holders from trust income, above the trust's operating costs and related expenses.

If you keep money in M-Pesa, that money is already earning income. Providers must hold customers' money in a trust, and the trust invests it. When Vodafone sold the M-Pesa trustee company in 2023, its disclosures described the holdings as cash, deposits and Treasury bills. Under current rules, the income goes to charity rather than to wallet holders.

Treasury and CBK published the draft Policy and the National Payment System Bill, 2026 on September 21. The Bill would replace the 2011 National Payment System Act and, among other changes, raise the minimum capital for e-money issuers from KES 20 million to KES 250 million. Njoroge's comments are a submission to that process, and he is asking for something the drafts do not contain.

Where the money goes today

When you put KES 1,000 into M-Pesa, Safaricom does not add it to its own accounts. The 2014 National Payment System Regulations require a provider to hold customer money in a trust, keep the balance at least equal to what it owes customers, and keep it out of its operating accounts. For M-Pesa, the trustee is M-Pesa Holding Company Limited, which Safaricom has owned since 2023.

The income the trust earns is covered by regulation 25(5). It says the income is to be used in line with trust law and in consultation with CBK, and donated to a public charitable organisation for public charitable purposes. How it is applied in practice is set out in the trust deed, which CBK must approve. Business Daily has reported that M-Pesa Foundation, Safaricom's charitable arm, has operated on this income.

Your KES 1,000 stays KES 1,000. What the pool earns is a separate question.

How big is the pool

When Vodafone sold the M-Pesa trustee company in September 2023, it reported €1.156 billion due to M-Pesa customers. At CBK's exchange rate of KES 147.30 to the euro on October 1, 2026, that is roughly KES 170 billion. It is a 2023 snapshot of M-Pesa alone, so it does not establish the size of today's pool, and Airtel Money is not included.

Applying three rates to it gives a range. At 3.54%, the average savings rate CBK reported for August 2026, the pool would earn about KES 6 billion a year. At 5%, about KES 8.5 billion. At 8.78%, the 91-day Treasury bill rate listed on CBK's website on October 1, about KES 15 billion. These are illustrations before trust costs, not reported returns earned by the M-Pesa trust. For KES 1,000 held for a year, the same three rates give roughly KES 35, KES 50 and KES 88.

What Njoroge wants changed

Njoroge sets out the principle and leaves the mechanics open. His comment is a single paragraph asking for the Policy and the payment laws to be amended to require regular bonus payouts. It gives no share, frequency, formula, eligibility rule or treatment of dormant balances.

His reasoning has four parts. Wallets are customers' legal financial property. Providers in Tanzania, Uganda and Ghana already do something similar. Expectations that wallet holdings would stay small were overtaken, and fears of competition with banks have dissipated. Business Daily quotes him calling the charity arrangement "a holdover from the industry's nascent phase." Business Daily also reported in April 2024, citing an IMF report, that mobile money customers in Uganda and Tanzania already earn interest on their balances.

What the draft Bill says

The 2014 rules say trust income shall be used under trust law, in consultation with CBK, and donated to charity. Clause 40 of the draft Bill says it may be used for charity, with CBK's approval, or for another purpose set later. "Shall" has become "may," and a second use has been added.

What the clause leaves out matters. It does not name wallet holders, mention interest or give a formula, so nothing in the draft pays you on its own. It also drops the reference to trust law and does not say what happens to income that goes to neither purpose. The Bill appears to leave any new purpose to regulations, which the Cabinet Secretary can make for trust arrangements under clause 76. It does not say whether paying customers could be one. CBK would still have to approve the use, and Parliament has to pass the Bill first, so Treasury, CBK and lawmakers all have a say before any shilling reaches a wallet.

What else Njoroge wants changed

Agent interoperability

Could you walk into an Airtel agent and cash out M-Pesa? The Bill does not clearly say so. Njoroge wants agent sharing named as a goal, so any customer could use any authorised agent and agents could manage one combined float. The Policy is silent on it. Clause 28 of the Bill requires providers' systems to work with other providers' agents and lets CBK order the arrangements, but it does not mention shared float. What changes at the counter depends on what CBK orders.

Fraud liability

Njoroge says fraud persists despite existing protections and wants the Policy to set principles on prevention, liability and redress. Under regulation 28(5) of the 2014 rules, a provider is liable for transactions made without the customer's knowledge, but it can contract out of that where it proves customer fault or shows at first glance that the legitimate customer carried out the instruction. Regulation 38(c) requires a mechanism for complaints about losses through fraud. The Star reports that the draft Policy proposes consumer dispute and fraud-liability frameworks. The Bill is thinner. Clause 51(3) requires beneficiary providers to keep systems and controls against misdirected payments and fraud, clause 42(2) allows payments settled because of fraud, error or mistake to be recovered in a manner to be prescribed, and clause 53 lets the Cabinet Secretary make rules on preventing payment fraud. If a scammer empties your wallet, none of those provisions says who pays.

The state's role in payments

The draft Policy commits the government to developing a national instant payment switch to move money quickly and cheaply across providers. Njoroge accepts that a government-owned entity could run a platform for public services, such as one replacing eCitizen, but says it would be problematic for government to compete directly with private firms in the wider market. He notes that government already holds stakes in Safaricom, Telkom Kenya and KCB Group, and that the design of the switch will probably be the first test of where the line sits.

The Bill does not mention the switch by name. Clause 16(5) lets CBK establish, own or operate financial market infrastructure related to its mandate, clause 6(2) exempts systems CBK operates or co-operates from licensing, and clause 9 exempts government-owned enterprises from licensing while still requiring CBK authorisation.

Safaricom and the Kenya Bankers Association made a different objection in a joint report in early 2025, reported by TechCabal in January 2025. They estimated that a CBK-led fast payment system could cost at least KES 25.9 billion and take up to four years, and proposed upgrading PesaLink, the bank-owned interbank system, instead. Those figures are their estimate, not an established cost.

What happens next

For wallet users, the open question is whether the income their balances generate remains directed to charity under CBK-approved rules or becomes something they can share in.

Public comment on both documents is open until Friday, October 9. Submissions go to the Governor of CBK by email to paymentslawreview@centralbank.go.ke, by post to P.O. Box 60000-00200, Nairobi, or by hand at the Governor's office on Haile Selassie Avenue, using the comment templates on the Treasury and CBK websites. Public forums continue in Nyeri and Kitale on October 2, Meru and Nandi on October 5, and Garissa and Nakuru on October 7, ending at the Kenya School of Government in Nairobi on October 9.