Affordable housing finance

Unlocking affordability: Reflecting on the affordable housing incentives program

March 3rd, 2026

Access to dignified and affordable housing has long been a profound aspiration for millions of Kenyans. However, for years, this vision was consistently hindered by high development costs, protracted regulatory procedures, and limited access to tailored financing solutions.

With Kenya’s urban population growing at 4% annually, the housing crisis reached a critical point where approximately 60% of Nairobi’s population lived in informal settlements that occupied just 6% of the city’s land. By early 2025, the national housing deficit was estimated at a staggering 2 million units.

In parallel, the housing sector is estimated to contribute 19.4% to Kenya’s GDP (Habitat for Humanity Cornerstone of Recovery Report 2021). Therefore, enabling housing supply through these tax incentives will help bridge the affordability gap for the offtake, and this should lead to a multiplier impact on GDP that is much more significant than the loss in the tax revenue from the incentives provided. While Kenya has provided tax incentives in law, these are hard to achieve in practice.

To address these systemic barriers, Financial Sector Deepening (FSD) Kenya partnered with Kenya Property Developers Association (KPDA) to establish the Affordable Housing Incentives Program, aiming to bridge the gap between policy and practice, guiding developers through the complex web of tax incentives and regulatory approvals that were essential for accelerating delivery. Examining the program’s implementation, it is clear how tax policy served as the anchor for project viability.

Findings of the open access analysis: The critical role of VAT incentives

A cornerstone of our program’s legacy was the open access analysis, which utilised anonymised, project-level data from private developers to peel back the curtain on the true cost of affordable housing in Nairobi. Our analysis of three active affordable housing projects in Nairobi revealed that the financial weight of Value Added Tax (VAT) is not a marginal detail—it is a fundamental driver of construction costs.

  • Direct delivery savings: The data demonstrated that VAT relief on construction and infrastructure averages 11% of the total project delivery cost.
  • Per-Square-Meter reduction: In practical terms, this relief translates to a reduction in average hard costs of between KShs. 6,000 and KShs. 8,000 per square meter.
  • Protecting developer margins: With affordable housing operating on razor-thin equity Internal Rates of Return (IRR) of approximately 9.5% (compared to over 20% for high-end developments), this 11% saving is the critical buffer that protects project bankability.

The analysis also highlighted a direct correlation between fiscal policy and the volume of housing stock developers can realistically bring to market.

  • Enabling below-market pricing: To meet the government’s ambitious price points—such as KES 35,000 for social housing and KShs. 42,000 for affordable housing—the current hard costs of construction (which remain between KShs. 38,696 and KShs. 55,364 psm even with exemptions) must be lowered.
  • The zero-rating recommendation: While the current VAT exemption under the First Schedule of the VAT Act (Cap. 476) provides relief, it fails to remove “embedded” taxes paid by manufacturers on their inputs. Our analysis suggests that a shift to zero-rating would allow the entire supply chain to reclaim input VAT, truly stripping the tax cost out of the project.
  • The efficiency gains: Moving to zero-rating would reduce overall project expenses by an estimated 8–10%. This reduction is an essential prerequisite for making the construction of housing at target price points a financially sustainable endeavour, allowing developers to scale their pipelines toward the national target of 250,000 units annually.

The mechanics of tax incentives: VAT and corporate tax

The program’s focus on fiscal incentives recognised that housing construction is a powerful economic multiplier, contributing an estimated 19.4% to Kenya’s GDP as stated above. We focused on two primary instruments:

  • VAT exemption: Currently, affordable housing materials are classified as VAT-exempt under the First Schedule of the VAT Act (Cap. 476). However, the program identified that under an exemption, manufacturers cannot reclaim VAT paid on their own inputs (such as clinker for cement), meaning “embedded” tax costs at 16% of the manufacturer’s cost base remain baked into the final price. KPDA strongly recommends a shift from this current exemption to zero-rating to allow the entire supply chain to reclaim input VAT.
  • Corporate tax reduction: To encourage scale, the program highlighted that companies constructing at least 100 units annually qualified for a 15% corporate tax rate—a reduction from the standard 30%. This 15% rate, as outlined in the Third Schedule of the Income Tax Act, is a calibrated instrument used to make constrained economics palatable for private investment.

The application journey: Navigating a complex roadmap

The program operationalised the application process into clear steps:

  • The VAT exemption process: Developers first register as a “Strategic Partner” with the State Department for Housing and Urban Development (SDHUD). They then prepare technical documents (Master List, BoQ, and Approved Drawings) for review by SDHUD, the National Treasury, and KRA to receive the final Exemption Letter.
  • Corporate tax application: This involves submitting a formal application to SDHUD along with a Certificate of Incorporation, Tax Compliance Certificate, and an Occupation Certificate from the County. Upon verification, the Cabinet Secretary issues an incentive certificate for use during annual filings.

Challenges: The “black box” of bureaucracy

Despite these benefits, developers must navigate over 10 different agencies to secure up to 28 separate approvals. A significant challenge is the “black box” of county governments; once an application is submitted, developers often lose all visibility into the review chain. These delays inflate financing costs and threaten project viability. By April 2025, while 12 VAT applications had been submitted, none had yet received formal Treasury approval due to these bureaucratic logjams.

A strategic outcome: The DATS System

A direct outcome of this work was the development of the Development Approvals Tracking & Support (DATS) System. This framework was designed to institutionalise learnings by providing a permanent mechanism for tracking and support. KPDA now calls for the uptake of the DATS system by industry associations to collaboratively monitor approval timelines. This is essential to promote facts-based advocacy and accountability, providing the evidence needed to ensure that excessive delays do not cause vital housing projects to stall.

The bottom line and strategic lessons

The program proved that when developers are empowered and systems are streamlined, momentum follows. To build on this, we conclude with several critical recommendations:

  • Unlocking the backlog: Prioritising leadership engagement to set a strict 30-day turnaround for compliant tax reviews.
  • Digitisation of the workflow: Advocating for a unified one-stop shop to integrate approvals into a single, transparent, and trackable workflow.

The program has laid the groundwork to ensure that the constitutional right to adequate housing can finally become a reality for all Kenyans.


Click here for the full Affordable housing tax incentives program report 

Click here for the Affordable housing tax incentives program’s developer financials 

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