19/08/2026
The Cost of Credit and the In Duplum Rule in Kenya
The cost of credit remains an important compliance issue for lenders and borrowers alike. Recent Kenyan jurisprudence continues to raise important questions about the accumulation of interest and penalties, particularly beyond traditional banking institutions.
The Banking Act, particularly Section 44A, provides the statutory framework for the in duplum rule for institutions within its scope. The broader principle has also been considered in cases involving non-bank lending.
Judicial guidance:
In Anne J. Mugure & 2 Others v Higher Education Loans Board [2022] KEHC 11951 (KLR), the High Court held that interest and penalties exceeding the principal amount violated the in duplum principle and stated that the rule applies to persons engaged in lending money.
The Court's reasoning is particularly significant for lenders outside the traditional banking sector, although the precise scope of the decision continues to be tested in subsequent litigation.
More recently, Kenyan courts have continued to scrutinize the legal framework governing non-bank lending and the enforceability of excessive credit charges. This makes transparent pricing, clear contractual terms, and appropriate regulatory licensing increasingly important for lenders.
Key compliance considerations for lenders:
• Clearly disclose interest rates, fees, penalties and other credit costs.
• Ensure lending activities are conducted under the appropriate regulatory licence.
• Review pricing models and default charges for proportionality and legal compliance.
• Maintain clear loan agreements and adequate records of customer disclosures.
• Regularly review lending practices against evolving judicial and regulatory requirements.
For borrowers, the lesson is equally important: a contractual interest rate is not necessarily immune from legal scrutiny simply because it was agreed upon.
For lenders, sustainable credit pricing requires more than commercial viability—it requires regulatory compliance, transparency and fairness.
At Madowo A Advocates, we advise lenders, businesses and borrowers on credit agreements, regulatory compliance, financial services law, debt recovery and lending risk.