What should open to the public first.

Product research from 5 Nov 2026. One recommendation, the evidence behind it, and the reference data. Written for Stanley. Published openly.

Read the answerReference data

The answer

• Open first

  kTown merchant QR

  Sats in, M-Pesa out. Never holds money. A Kisumu pilot of 10 shops, free, four weeks.

  The pilot plan
• Not yet

  Ye₿ente wallet

  The wallet works, but it holds users’ sats. Opening it wider waits for legal advice under Kenya’s VASP Act.

  Why it waits
• Stay inside

  Everything else

  Marketing engine and ops tooling stay internal. Learning content stays free. Donations stay open.

  What stays closed

This is research, not legal advice. Points marked to confirm need a check before anyone acts on them.

Top risks

• !Kenya now licenses virtual asset services.
  Every service here gets legal advice before it opens to more people.
• !One Mac over a tunnel is a single point of failure.
  If the Mac sleeps, the node goes dark. Fine for a pilot. Not for strangers at scale.
• !Words must stay honest.
  Ye₿ente is custodial: Altradits holds the sats and can freeze sends for safety. The homepage wording was fixed in Nov 2026. No page may claim otherwise.
• !Tando is partner and rival.
  kTown rides Tando's rails. Tando could build merchant QR itself. The edge is local trust and Kiswahili support, not tech.
• !One person caps everything.
  Support, liquidity, and incidents all land on Stanley. Caps on users and amounts keep one bad day survivable.

What exists today

Read from the code on 5 Nov 2026, not from guesses. Live state checked the same day.

Why kTown first

A Kisumu shop prints one QR. Any Lightning customer pays. The shop gets exact KES in M-Pesa. No wallet for the merchant. No hardware. kTown never holds money: sats go payer to Tando to M-Pesa, and Tando takes 1%. It is the only money-moving candidate that can plausibly open without a licence. The lawyer confirms.

• The direct alternative is the Tando app and API itself: zero-fee checkout, and every M-Pesa number already works as a Lightning address.
• BTCPay Server is free and non-custodial, but technical: a server and a node or provider.
• Kotani Pay offers stablecoin on and off ramp rails for builders.
• The edge is a printed QR, the exact KES promise, Kiswahili, and a human who visits the shop.
• Honest money: no revenue at launch. Later options are a flat till fee or a small add-on, lawyer first, since fee taking may change the licensing answer.

Why Ye₿ente waits

The wallet is the best tech here. It is also custodial: the server ledger holds user sats on Stanley’s node. Custodial services have their own rules under Kenya’s Virtual Asset Service Providers Act 2025, so it stays a learning wallet while that advice is taken.

• Rivals that avoid custody: Tando (non-custodial), Bitika (sats to your own wallet), Machankura (Lightning over USSD), Blink (open source, StableSats). Also in the space, depth in Kenya to confirm: Fedi, Wallet of Satoshi, Zeus, Bitnob.
• Money math: revenue is zero today (spread 0, sends free). 100 buys a month at 1,000 KES with a 1% spread is 1,000 KES a month. Growth waits for the legal answer.
• Scale math: 1,000 wallets at the 200,000 sat cap is 200M sats (2 BTC) of Stanley's outbound liquidity. The solvency check watches it. Funding it is real money.

The 30-day pilot

10 shops in Kisumu Stanley can visit on foot. One printed QR each. KES only. 15 to 50,000 KES per payment. No fees from Altradits. Kiswahili and English.

1. Days 1 to 7Clearance and fixesLegal advice sought. Print flow, terms page, and abuse blocklist built and tested. Intro email to Tando sent.
2. Days 8 to 14First shopsAnswers in. KTOWN on. 3 friendly shops onboarded. First real payments watched in person.
3. Days 15 to 21Ten live10 shops live. Visit each. Log every failure and every support ask.
4. Days 22 to 30DecideGrow (more shops, second town) or stop. The signals below decide.

Grow signals

• ✓8 or more of 10 shops still show the QR.
• ✓Repeat customer payments, not just demos.
• ✓Support under 30 minutes a day.
• ✓A shop asks for a second QR or refers a neighbour.

Stop signals

• ✕Tando blocks or rate limits the use.
• ✕Any payment lands wrong: amount or number.
• ✕Legal advice says to wait.
• ✕Support passes 1 hour a day for 10 shops.
• ✕Merchants stop showing the QR.

Stanley does himself: legal advice, the Tando email, the printing, and the shop visits. No new accounts needed. No Daraja, no Pesapal, no Bitika live key for kTown.

What stays closed

• Ye₿ente for strangers. It holds users’ sats, so it waits for legal advice.
• Buy sats and card top-up for strangers. Same reason, plus sandbox keys that must never face the public.
• Telebirr. No partner, no testing. A config flag is not a product.
• Marketing tool, ops tooling, and the contact shield as services. Single-user internals. Selling them burns the one person who keeps the node safe.

Reference data

Key dates

• 4 Nov 2025: the VASP Act commenced.
• 22 Jul 2026: the VASP Regulations gazetted (Legal Notice 134).
• 4 Nov 2026: the one year transition ended.
• 5 Nov 2026: this research reviewed.

Fees today

• Tando: 1%, kept by Tando. Bitika: 3%, kept by Bitika.
• Altradits: Buy spread 0, handle sends free. Revenue hooks exist and sit at zero.
• Tando address claim: KES 210 over M-Pesa. Contact form: $1. Tips: 10 to 5,000,000 sats.

Caps in the code

• Wallet 200,000 sats. Payment 100,000 sats. Daily send 200,000 sats. Recovery hold 1,000 sats.
• Send Mobile 15 to 50,000 KES. Bitika buy 10 to 10,000 KES per payment.

Settings that gate features (names only)

KTOWN, YEBENTE_WALLETS, YEBENTE_MPESA_BUY, YEBENTE_BITIKA_BUY, BITIKA_API_KEY, YEBENTE_BUY_PROVIDER, YEBENTE_CARD_BUY, PESAPAL_ENVIRONMENT, YEBENTE_BUY_SPREAD_PCT, YEBENTE_MAX_BALANCE_SATS, YEBENTE_MAX_PAYMENT_SATS, YEBENTE_DAILY_SEND_SATS, YEBENTE_RECOVERY_HOLD_SATS. See .env.example in the repo.

Live snapshot, 5 Nov 2026

Partner links

• Tando developer docs and the address claim page.
• Bitika developer portal (test keys) and Bitika docs.

Sources

• Regulation: ENSafrica on the VASP Act, the 4 Nov deadline, Vellum on compliance, LawLab countdown, the CBK and CMA split, licence capital table, licence seekers, ODPC registration.
• Market: 40M Lightning addresses, Tando interview, Bitika guide, Bitika profile, Bitika outage note, Machankura on feature phones, Blink in a Kenyan village, Kotani Pay.
• Code: docs/yebente.md, docs/ktown.md, lib/ywallet.js, lib/ktown.js, lib/rails.js, lib/bitika.js, api/yebente.js, api/ktown.js, server.mjs, DEPLOY.md, in the repo.

Method

Read-only review of the main branch plus live GET checks and public sources on 5 Nov 2026. Every rival and rule links its source. Gaps say to confirm. Research, not legal advice. Questions go through Contact.