Mandatory inbound travel health insurance cover for foreign visitors in Kenya: Opportunities and challenges

The Ministry of Health has introduced mandatory inbound travel health insurance for international visitors. Every foreigner coming into Kenya will now need to demonstrate a proof of travel health insurance with a minimum coverage of $50,000. While this is a significant policy shift aimed at ensuring foreigners bear their costs of medical treatment without burdening the local government financially, it also presents various challenges.

The Social Health Insurance Act, 2023, (the Act) under its Section 26(6) mandates a non-Kenyan person who intends to enter and remain in Kenya’s territory for a period of less than twelve months to possess a travel health insurance (the Insurance Cover), as may be designated by the Cabinet Secretary responsible for matters relating to health. Section 26(7) of the Act mandates the Cabinet Secretary to give effect to Section 26(6), by establishing policy, regulatory or administrative measures. 

The Ministry of Health's Administrative Framework for Implementation of the Mandatory Inbound Travel Health Insurance Program (November 2025) (the Framework) clarifies how this "entire period of stay" requirement operates in practice. The Insurance Cover is tiered by length of stay: 

(i) single entry cover for stays of up to 30 days from the date of entry; 
(ii) single entry cover for stays of between 31 and 60 days; and
(iii) international Private Medical Insurance (IPMI) for any stay longer than 60 days, up to the maximum 12-month period contemplated by the Act.

The Social Health Insurance Regulations (the Regulations) were enacted in 2024 to give effect to the Act. Regulation 70(2)(a) of the Regulations provides that the Insurance Cover shall cover the person’s entire period of stay in Kenya. Such a person travelling may obtain the Insurance Cover at the point of entry in Kenya. Regulation 70(2)(b) of the Regulations mandates the Insurance Cover to provide for benefits including personal accident that may lead to death or permanent total disability, emergency medical expenses, emergency medical evacuation, repatriation of mortal remains, hospital benefits and prescription medicines. 

It is against these enabling provisions of the Act and Regulations that the Cabinet Secretary for Health, through a Gazette Notice No. 11492 dated 29th July 2026 (the Notice), gave notice of the minimum policy benefits for the Insurance. In particular, the Insurance cover will provide the following policy benefits and insurable limits as a minimum: United States Dollars Fifty Thousand (USD 50,000), including coverage of at least United States Dollars Twenty Thousand (USD 20,000) for medical expenses, United States Dollars Twenty-Five Thousand (USD 25,000) for emergency medical transportation, United States Dollars Three Hundred (USD 300) for prescribed medicines, United States Dollars One Thousand (USD 1,000) for mental illness treatment, and United States Dollars Five Thousand (USD 5,000) for repatriation of mortal remains. While the benefit limits under the Insurance Cover may vary across different categories, the Notice stipulates that the cumulative benefit limit shall not be less than USD 50,000, figures that mirror the minimum schedule of benefits already set out in the Framework.

Enforcement of the Notice: An opportunity for Kenya?

Importantly, Gazette Notice No. 11492, issued pursuant to section 26(6) of the Social Health Insurance Act 2023 and Regulation 70(2)(b) of the Social Health Insurance Regulations 2024, expressly provides that mandatory inbound travel health insurance must be underwritten by insurers that are duly approved and licensed under the Insurance Act (Cap. 487). Accordingly, the cover cannot be provided by the Social Health Authority itself, whether for Kenyan or non-Kenyan travellers. In addition, any insurance product offered to the public must comply with the regulatory approval requirements applicable under the Insurance Act and be issued by an insurer authorised and regulated by the Insurance Regulatory Authority (IRA). This presents a strategic opportunity for Kenya to expand its local insurance sector while also contributing to the growth of Kenya’s economy. 

Kenya has opted for a designated provider model in sourcing for the Insurance. According to the 2025 Framework, the prerogative to select a local insurer falls with the Ministry of Health. This approach requires local insurers to meet stringent financial thresholds and demonstrate operational capability, including nationwide coverage, before they can participate, in particular, the Framework requires the local insurer to show a Gross Written Premium in Kenya of over Kenya Shillings Two Billion (KES 2,000,000,000) (approximately USD 15.5 million) and a claims-settlement track record of over Kenya Shillings Fifty Million (KES 50,000,000) (approximately USD 387,600) in each of the preceding two financial years. in each of the preceding two (2) financial years, to be reinsured by an international reinsurer with a capital base exceeding United States Dollars Ten Billion (USD 10,000,000,000 ) and more than Thirty (30) years' global experience, and to work with or act as a third-party administrator with over 50 years' experience serving at least Two (2) million lives. Notably, the Framework also proposes that the successful provider be granted a contract term of between ten (10) and twelve (12) years to recoup its investment in technology, infrastructure, and stakeholder engagement, a point that existing and prospective bidders may wish to scrutinise given the earlier discrimination complaints referenced below. 

The Kenyan Government, through the State Department for Immigration and Citizen Services, had invited local insurers in December 2024 through a restricted tender for the provision of the Insurance Cover. This, however, failed due to backlash by local insurers who complained of discrimination. Notwithstanding the failure of the initial procurement process, the Government has since proceeded to prescribe the minimum benefits and coverage limits for mandatory inbound travel health insurance through Gazette Notice No. 11492. Accordingly, while the policy requirement for inbound travel health insurance appears set to proceed, the implementation framework remains subject to the establishment of a lawful and transparent procurement mechanism. It is therefore likely that the Government will revisit the procurement structure, whether through a fresh competitive tender, a revised designated provider model, or a broader multi-insurer framework, in order to address industry concerns, promote competition and ensure compliance with applicable public procurement laws

From a public policy perspective, the Insurance Cover has a legitimate objective since medical emergencies involving foreign visitors to Kenya may be unusually costly. Hospitals deserve certainty of payment, and the government has a legitimate reason to ensure that the costs of emergency treatment, medical evacuation or repatriation do not ultimately fall on taxpayers and public institutions. 

Many destinations globally, including countries in Europe (the Schengen area), the United Arab Emirates, Egypt and Russia, have implemented the requirement of mandatory travel insurance for foreigners, especially after the COVID-19 pandemic. The Notice therefore ensures that the Kenyan healthcare system is prepared to deal with any public health emergency. 

Is Kenya’s tourism sector at risk? 

While Kenya is optimising for risk management, the mandatory Insurance Cover invites the question of whether it could discourage international travellers from visiting Kenya considering tourism operates in one of the most competitive markets globally. The international travellers might instead opt for other competing destinations, instead of Kenya. 

Moreover, as many long-haul travellers already travel with comprehensive insurance purchased in their home countries or included in their travel packages which may be providing equal or better insurance coverage than Kenya’s minimum requirements, they would be compelled to purchase another local policy which could add little or no additional value. It simply replicates the existing cover and may subsequently, increase the cost of entry into Kenya. 

A further related consideration is data privacy. The Framework contemplates that travellers will submit extensive personal information, including passport biodata, a facial photograph, and disclosure of any underlying medical conditions and medicines not easily accessible locally, through a dedicated "Kenya Cares" e-portal (www.kenyacares.go.ke). Because health status is classified as sensitive personal data under the Data Protection Act 2019, the designated insurer, any third-party administrator and any re-insurer handling this data, including where it is processed or stored outside Kenya, will need to demonstrate robust compliance with the Data Protection Act, the Digital Health Act 2023, and, where data is transferred internationally, standards such as the GDPR. Any perception that traveller data is inadequately protected, or that consent is not meaningfully obtained, could itself become a deterrent to visitors and a source of regulatory and reputational risk for the designated provider.

Conclusion 

The legal requirement for a non-Kenyan that intends to enter and remain in Kenya for less than twelve months to possess a travel health insurance Cover is now in force although the Ministry of Health is yet to publish a list of approved insurers. 

The directive protects foreigners coming into Kenya from costly medical costs while also reducing the financial burden on the Kenyan public health system. The key to success of enforcement of the Insurance Cover will be ensuring that the premiums remain affordable and that claims are settled promptly. Robust data protection safeguards, together with effective oversight by the newly constituted Committee and Secretariat and the 24/7 multilingual call centre the Framework requires of the designated provider, will also be central to building public confidence in the scheme. Clear regulation and digital verification will strengthen Kenya’s reputation as a safe and welcoming tourist destination while also supporting various critical sectors such as insurance. It remains to be seen how the Insurance Cover will be enforced in practice. 

Will it present an opportunity for Kenya or will it present other challenges such as the fall of tourism revenue? Follow our article series as we delve into these developments in insurance, navigate complexities and explore potential solutions.

Should you have any questions regarding insurance matters, please do not hesitate to contact Jared Kangwana on Jared.Kangwana@clydeco.com or Nelly Tuitoek on nelly.tuitoek@clydeco.ke, who will be pleased to assist.