By the NGOs.ke Editorial Team.
Corporate donations to Kenyan NGOs work best when the NGO can prove two things: that it holds a valid KRA income tax exemption certificate, and that its work lines up with something the company already cares about. As of October 2026, the first is a legal requirement for the donor to claim a tax deduction under the Income Tax (Charitable Organisations and Donations Exemption) Rules, 2024. The second is what separates a one-off cheque from a multi-year partnership.
This guide covers both sides: what companies need before they can give tax-efficiently, and how NGOs can build a pitch that a corporate foundation or CSR manager will actually say yes to.
What do Kenya’s 2024 donation rules mean for corporate donors?
The Rules were gazetted as Legal Notice No. 105 of 2024 and took effect on 18 June 2024. KRA’s public notice says donation deductibility sits under section 15(2)(w) of the Income Tax Act, and that organisations with existing exemptions were given a one-year transition that ended on 18 June 2025. Organisations that cannot show compliance risk having their exemption revoked.
For a company deciding where to give, the practical effect is simple. Before cutting the cheque, ask for the NGO’s current exemption certificate. According to EY’s summary of the Rules, a donor should also hold the receipt issued by the exempt organisation, the organisation’s approved budgets, and a declaration that the gift supports charitable purposes only. EY also notes that a donation cannot be used to create a taxable loss, and that the donor’s giving in a year should not go mostly to unrelated entities.
This is a summary, not tax advice. Both NGOs and donors should read the Rules themselves and check with a tax adviser.
Key facts at a glance
- Legal basis: Income Tax (Charitable Organisations and Donations Exemption) Rules, 2024 (Legal Notice No. 105 of 2024).
- In force from: 18 June 2024; transition for existing exempt organisations ended 18 June 2025.
- What donors need: the NGO’s exemption certificate, an official receipt, and supporting documents as set out in the Rules.
- Exemption certificate validity: five years, with renewal applications due six months before expiry (per EY).
- KRA decision window: about 60 days on a complete application (per EY).
- Surplus cap: exempt organisations may accumulate surplus funds not exceeding an average of 15% over three succeeding years (per EY).
Is corporate CSR about to become mandatory in Kenya?
Not yet. In October 2025 the Kenya National Innovation Agency (KeNIA) said it had begun drafting a proposal for a framework that would channel part of large companies’ CSR budgets into a national innovation fund, modelled on India’s Companies Act of 2013, which requires qualifying firms to spend at least 2% of average net profit on CSR. KeNIA’s chief executive, Tonny Omwansa, said the target was to mobilise KES 4.5 billion. The proposal is aimed at startups and innovators, and the reports available at the time gave no percentage or timeline for Kenya. NGOs should treat it as a trend to watch, not a funding source, and keep an eye on whether any final policy leaves room for charitable programmes.
How do you pitch a company for a partnership?
WWF Kenya’s experience is a useful public example. In a case study published by WWF Switzerland, the Kenya team grew its corporate partners from three to five and reported partnership value of CHF 15 million. Its partners included SBM Bank (a sustainable marine programme tied to a debit card), NCBA Bank (a tree-planting commitment under the “Keep Kenya Breathing” campaign) and Sankara Nairobi. The team’s own lesson was to find shared values first, then tailor the offer, and to favour a few strong relationships over many shallow ones.
You don’t need WWF’s scale to borrow the method:
- Start from the company’s business, not your budget. A bank cares about financial inclusion and youth savings. A water utility cares about catchments. Name the overlap in your first paragraph.
- Offer a bounded project with a number attached. “Equip two classrooms in Laikipia and report on attendance after a year” is easier to approve than “support our education work”.
- Lead with compliance. Attach your exemption certificate, registration documents and latest audited accounts. Finance teams approve faster when the paperwork answers their questions up front.
- Promise reporting you can deliver. A short quarterly update beats a glossy annual report nobody reads.
- Involve senior people on both sides. WWF Kenya credits leadership involvement for its results.
What should an NGO prepare before approaching donors?
Get the basics in order first. If your exemption has not been secured or renewed, start with our KRA tax exemption guide for NGOs. Make it easy for supporters to give with the setup in our M-Pesa donations guide, and put the request on paper using our grant proposal guide. If your funding mix is shifting, our look at Kenya’s NGOs after USAID explains why diversifying toward local corporate giving matters.
The authoritative text of the Rules, and KRA’s implementation notice, is on the Kenya Revenue Authority website.
Frequently asked questions
Can a company deduct donations to any NGO in Kenya?
No. Deductibility depends on the recipient meeting the conditions in the 2024 Rules, which start with holding a valid exemption certificate from KRA.
Do small CBOs qualify for corporate donations?
A company can give to any group it likes, but it can only claim the tax benefit if the recipient is an exempt organisation. Small groups often partner with a registered, exempt NGO that acts as fiscal host.
Is CSR compulsory for Kenyan companies?
Not at present. KeNIA’s October 2025 proposal for a CSR framework was still at the drafting stage in the reports we reviewed.
How long does an exemption application take?
EY’s summary of the Rules puts KRA’s decision window at 60 days from a complete application, with certificates valid for five years.
What do companies want to see in a proposal?
A clear project, a budget, compliance documents and a reporting plan. Alignment with the company’s own sector helps more than polished design.
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