Advertising a Money Market Fund in Kenya: CMA and Ad Rules

Before a money market fund in Kenya runs a single ad, two people outside the marketing team have to be involved: the scheme’s trustee, who approves it in writing, and the Capital Markets Authority, which is notified. Skip either step and the ad does not meet regulation 163.

This guide is for the marketing and compliance teams at Kenyan fund managers, trustees and investment platforms. It sets out what the Capital Markets (Collective Investment Schemes) Regulations, 2023 require of an ad, what Google and Meta add on top, and a short checklist to run before launch. Every rule below is tied to the regulation or policy page it comes from, with the date we read it.

Who approves a money market fund ad in Kenya

The short answer: the trustee signs it off, and the CMA is told about it. Regulation 163(1) of the CIS Regulations says a person shall not advertise a collective investment scheme to the public in any media “unless the advertisement has been approved by the trustee in writing and notified to the Authority.”

That is a notification, not a pre-approval. The rule does not say the CMA must clear the ad before it runs. We found no published CMA form or process for making the notification, so ask the trustee or your CMA contact how they want it done, and keep the record.

What counts as an advertisement

Regulation 163(2) defines it widely. It covers material for newspapers, magazines, brochures, fund fact sheets, offering documents, letters, websites, and “any other written or electronic material distributed to more than one party.”

• A Google search ad, a Meta carousel and an email to your newsletter list all count.
• So does the landing page they point to.
• On that wording, so would a fact sheet sent to a WhatsApp broadcast list.

Only a licensed person may advertise a scheme

Regulation 4(1)(c) goes further. A person shall not “advertise or cause to be advertised in Kenya, a scheme advertisement unless that person is a licensed person,” and the contents must be approved by the trustee and comply with Part XIV, the advertising rules. Breaching regulation 4 is an offence under regulation 4(2).

This matters for anyone who promotes a fund on its behalf: affiliates, influencers, comparison sites and agencies. The regulation does not say how it applies to each of them, and we are not going to guess. If someone other than the fund manager will run or publish ads, take legal advice on regulation 4(1)(c) before they do.

Platforms that distribute funds: CMA approval, 48 hours ahead

Investment apps and other intermediary service platforms face a stricter rule. Under regulation 82, a platform provider “shall seek approval from the Authority” of any advertisement or promotional material to the public at least 48 hours before the date of publication. That is approval, not notification. Build the two days into every campaign calendar.

If you are mapping these rules against other Kenyan regulators, our guide to who approves a fintech ad in Kenya sets the CMA’s rules beside the CBK’s, IRA’s and SASRA’s.

What the Capital Markets Authority requires on the ad itself

Approval is about process. Part XIV of the regulations is about content, and it is specific. These are the rules a reviewer will hold your creative against.

The three warnings

Regulation 164(3) requires every advertisement to include a warning that:

1. the price of shares (units), and any income from them, may go down as well as up;
2. past performance is not reflective of future performance; and
3. in certain circumstances, investors’ right to redeem may be suspended.

Regulation 164(4) adds that the warnings must be readable “with reasonable ease by anyone reading the advertisement.” A line of tiny grey text under a video is unlikely to meet that. On a short ad format, the practical answer is to carry the warnings in the creative where they fit and on the landing page in full.

Two disclosures people forget

• “Approved by the CMA.” If the ad says the scheme is approved by the Authority, it must also say that the Authority “does not take responsibility for the financial soundness of the scheme” or for the correctness of statements made (reg. 164(2)).
• Naming the trustee. Any ad that includes information on the trustee must be accompanied by the trustee’s written consent (reg. 164(1)).

Performance figures

The yield is usually the headline. It is also where the rules are tightest. Under regulations 167 to 169, the fund manager must:

• present performance fairly and fully, with nothing false or misleading (reg. 167);
• keep the data behind every figure in the ad, and say where to get the full performance report if the ad summarizes it (reg. 168);
• label the fund name and description, the benchmark where one is used, and the periods shown (reg. 169(1));
• show everything in one currency, and say which (reg. 169(2));
• present total returns as at least one-year, three-year and five-year annualized returns through the most recent period (reg. 169(3));
• disclose the expense ratio and which fees it includes, the risk in terms an investor will understand, and any sales charges (reg. 169(4)–(6)).

A fund younger than five years has a problem the regulations do not solve. Regulation 169(3) asks for five-year returns and does not say what a newer fund should show instead. We could not find guidance on it. Ask the trustee before you publish a yield for a young fund.

Two quick checks help. Does the headline number match a figure in the latest published report? And is the annualized-return table on the same page as the headline, not two clicks away?

Unit trusts in Kenya: the same rules, applied to every scheme

Nothing in Part XIV is specific to money market funds. The rules apply to any collective investment scheme, so equity funds, balanced funds, fixed income funds and dollar funds marketed as unit trusts in Kenya carry the same warnings, the same trustee sign-off and the same performance rules.

Where it gets heavier is the multi-fund ad. A platform or manager promoting several funds in one campaign needs regulation 169’s disclosures for each fund whose performance it shows: each fund’s name, periods, returns and expense ratio. The simplest compliant pattern is one ad per fund, each pointing to its own landing page.

For a platform, every one of those ads also goes to the CMA for approval 48 hours ahead under regulation 82. Promoting a new fund in an app’s marketing is a regulation 82 event, not just a product update.

Google Ads and Meta: the second gate on a money market fund in Kenya

The platforms sit on top of the law, not in place of it. Neither of them checks your trustee approval. Both can still stop your ad.

Google

• No financial-services verification for Kenya. Google’s verification programme covers 42 countries. Kenya is not one of them, and neither is any other African country.
• Local law still applies. Google’s policy says advertisers must comply with the regulations “for any location that your ads target,” including disclosures required by local law.
• Disclosures on the landing page, visible without a click or hover: the business’s physical address, all associated fees, and links to proof of any affiliation or rating you claim. A “licensed by the CMA” badge with no link to the CMA’s own listing is the kind of claim this rule is about.

Meta

• No financial-services verification for Kenya either. Meta lists ten regions that require it: Australia, Hong Kong, India, Ireland, Israel, Spain, Taiwan, Thailand, the UK and the US. For any country not listed, it says there is no verification requirement “at this time.”
• A licence can still be asked for. Meta lists investment products among the financial services that may require a licence, and says it may review an advertiser’s authorization. Its policy page, last changed on 29 October 2026, also says financial advertisers must verify their business or identity.
• The US-only rule does not apply. Meta’s extra restriction on investment ads applies to ads targeting the United States, not Kenya.

For the full platform picture across Kenyan financial products, including loans and forex, see our breakdown of financial services advertising regulations.

A pre-launch checklist for a money market fund ad

1. Trustee approval in writing for this exact creative and landing page (reg. 163(1)).
2. CMA notified, and the record kept (reg. 163(1)). Platforms: CMA approval requested 48 hours ahead (reg. 82).
3. The advertiser is a licensed person, or legal advice taken if anyone else runs the ads (reg. 4(1)(c)).
4. Three warnings present and readable (reg. 164(3)–(4)).
5. “CMA-approved” claim? Disclaimer added (reg. 164(2)). Trustee named? Trustee consent attached (reg. 164(1)).
6. Performance: fund name, periods, benchmark, one currency, 1/3/5-year annualized returns, expense ratio, risk, sales charges, and where to find the full report (regs. 168–169).
7. Google landing page: physical address, all fees, and links to proof of any claimed affiliation, all visible without a click.
8. Meta: licence documents ready in case Meta asks.

Our free fintech ad copy checker checks draft copy for rate disclosures, banned phrases and pre-approval gates, the CMA’s included, before it goes to the trustee.

FAQ: advertising a money market fund in Kenya

Advertising a money market fund in Kenya: what to do next

The order of work is the whole lesson. Write the ad, put the warnings and performance disclosures in, get the trustee’s written approval, notify the CMA, and only then build the campaign. Done the other way around, approved creative gets re-cut, or ads run that the trustee never saw.

If your fund’s ads are already live, run them against the checklist above. If you want a second pair of eyes on the whole acquisition setup, from tracking to ad approvals, that is what our Acquisition Audit covers, and our fintech PPC work is built around getting regulated ads approved and kept live.

This guide summarizes regulations and platform policies as we read them on 31 October 2026. It is not legal advice.