By the NGOs.ke Editorial Team.
What is the deadline for NGOs to transition to the PBO Act in Kenya? It is 14 May 2027. A gazette notice (Legal Notice No. 85) extended the transition period by one year on 14 May 2026. Organisations registered under the repealed NGOs Co-ordination Act do not re-register: the Public Benefit Organisations Regulatory Authority (PBORA) says their transition is automatic. But you still have to update your records with the Authority, and that is the part many boards are missing as of October 2026.
Key facts at a glance
| Item | What the notices say |
|---|---|
| Extended deadline | 14 May 2027 (one-year extension, gazetted 14 May 2026) |
| Legal basis | Fifth Schedule to the PBO Act, 2013: para 5(1) deems NGO Act registrants registered; para 5(2) allows the extension |
| Fresh registration? | No. PBORA Advisory No. 1 of 2026 describes the transition as automatic |
| What you must do | Update records under Regulation 43 of the PBO Regulations, 2026 |
| Outcome | New PBO certificate, with your original NGO registration details kept for continuity |
| Channel | eCitizen, according to press reports; the Authority was still operationalising its systems |
Do NGOs have to re-register as PBOs?
No, and that is the point that caused panic in May 2026. Days before the extension, the Interior Ministry had told NGOs to re-register under the new framework or risk deregistration. On 14 May, PBORA clarified that organisations registered under the 1990 Act do not need fresh registration. The Fifth Schedule deems them registered under the PBO Act by operation of law.
Law firm Cliffe Dekker Hofmeyr calls the process automatic but "not entirely passive": the Authority still needs your prescribed information to update its register and issue the new certificate.
What records must an NGO submit under Regulation 43?
Press reports of the notices list the following. Treat this as a working checklist and confirm the final list on the Authority’s portal, because the formal submission process was still being set up.
- Details of the organisation and its governing body.
- A revised constitution aligned with the PBO Act.
- Minutes with a board resolution approving the organisation’s entry into the PBO Register.
- A copy of the certificate issued under the repealed NGO law.
- Audited accounts, which Kenyans.co.ke lists among the documents to have ready.
The notices cover national and international NGOs. Reports also draw a line between organisations that implement activities directly in Kenya, which register, and those working only through funding and partnerships, which need permits.
What should your board do before May 2027?
- Find your original certificate and note the registration number. Donors will ask for both old and new numbers.
- Compare your constitution with the PBO Act. Flag clauses on governance, board terms and dissolution for amendment. Our PBO board governance checklist covers the board side.
- Hold a board meeting and pass a recorded resolution approving the transition. Keep signed minutes.
- Close your accounts. Have recent audited statements ready, and check that your PBO annual returns are filed.
- Watch for the portal. Submit as soon as the Authority opens the channel, not in April 2027.
- Tell your donors. Send a short note explaining that your legal status continues and a new certificate is coming.
What happens if you miss the deadline?
That is genuinely unclear. The Cliffe Dekker Hofmeyr alert does not say what follows after 14 May 2027, and no official guidance we found sets out consequences. Our existing explainer on PBO deregistration shows why waiting is a bad bet. Organisations that cannot show current records risk questions from banks, donors and regulators well before any formal penalty.
Frequently asked questions
Is the 14 May 2027 deadline for registration or for updating records?
Officially, the gazette notice extends the period to seek registration under the PBO Act. PBORA’s advisory says registered NGOs transition automatically but must update records. Plan on submitting your records before the date.
Will my NGO get a new registration number?
Reports say transitioned organisations receive new PBO certificates with updated registration numbers, while the original NGO details are retained for continuity.
Do I need to pay a fee to transition?
None of the sources we reviewed mention a transition fee. Confirm on the Authority’s portal before paying anyone who offers to "fast-track" the process.
Does this apply to international NGOs?
Yes. The notice covers both national and international NGOs, though direct implementers and funders working through partners are treated differently.
Where can I read the official background?
The Kenya News Agency explains the aims of the PBO Act in its report, PBO Act seeks to weed out briefcase NGOs. For the wider picture, see our guide to Kenya’s PBO Act 2026.
This article is general information, not legal advice. Check PBORA notices and the Kenya Gazette for current requirements.
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