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Kenya, November 13, 2026 - Kenya Revenue Authority Commissioner-General Adan Mohammed has linked tougher import-document requirements to a discrepancy between Chinese export figures and Kenya’s customs records, telling the 43rd ICPAK Annual Seminar that China recorded roughly $10 billion in exports against about $5 billion captured by KRA.
In a video of his remarks described to this publication, Mohammed said KRA approached China’s State Taxation Administration for information on exports to Kenya. He presented the comparison as part of the explanation for the documentation requirement introduced through Section 43 of the Finance Act, 2026.
The requirement, which took effect on September 1, obliges importers to obtain and retain export declarations or equivalent documents from the country of export. KRA’s published guidance confirms that businesses must produce these records when requested.
Mohammed’s explanation puts a substantial trade-data discrepancy at the centre of a rule that requires Kenyan importers to secure documentation relating to goods leaving another country.
According to the description of the seminar video supplied for this report, the Commissioner-General said China’s figures were approximately twice the amount captured in KRA’s customs records.
The original video and underlying datasets were not available for independent examination. The period covered by the comparison, the categories of goods included and any adjustments made to reconcile the figures therefore remain unverified.
Those details are essential. A difference between two countries’ trade records is not, by itself, proof that goods worth the entire difference were smuggled or deliberately undervalued.
It is also not a calculation of unpaid taxes. The figures attributed to Mohammed concern the value of trade, not an established revenue loss.
The documentation rule gives KRA an additional source of evidence against which to assess import transactions.
“From 1 September 2026, importers must obtain and retain an export declaration, export entry, customs export certificate or equivalent document from the country of export,” the authority states in its Finance Act implementation guidance.
The records should identify the exporter and importer and describe the goods, quantity, value, tariff classification and country of export. KRA says the document should support the importation of goods into Kenya.
In practical terms, the requirement adds evidence from the exporting side of a transaction to the paperwork supporting the Kenyan import.
That creates a basis for checking whether the information presented by an importer is consistent with the export record. However, the existence of a discrepancy does not establish its cause; investigators must still examine the relevant transactions and explanations.
The reported China comparison raises a further question: how much of the difference has KRA reconciled, and how much does it attribute specifically to inaccurate declarations?
The rule is already operational, rather than a proposal awaiting implementation.
KRA directs importers to request export documentation from suppliers, retain it for at least five years and produce it when required.
“Failure to produce satisfactory documentation may affect claims relating to value, origin, ownership, exemptions, deductions or refunds,” its guidance warns.
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For businesses, that means the records may matter beyond a routine document check. They can affect the evidence available to support the value of goods or a claim for particular tax treatment.
The verified guidance does not provide figures showing how many importers have been checked under the requirement, how many declarations have been challenged or how much additional revenue has been collected.
Similarly, this report has not independently established whether KRA has published a detailed reconciliation of the Chinese and Kenyan totals cited in the seminar remarks.
The distinction matters: the legal obligation is documented, while the scale and explanation of the reported trade discrepancy still require supporting data.
For importers, the immediate task is to secure the required records from suppliers and retain them alongside their transaction documentation. KRA’s guidance makes clear that the records must be available when requested.
A practical question concerns businesses buying through agents, intermediaries or consolidated shipments. They need clarity on which documents will satisfy KRA when the Kenyan purchaser is not dealing directly with the party that completed the export declaration.
The implementation challenge is therefore not simply whether a document exists. It is whether the importer can obtain it and demonstrate that it supports the goods imported.
This report has not established that the rule has caused widespread delays, additional charges or higher retail prices. Those effects would require evidence from businesses, clearing agents and customs records.
For KRA, the next accountability test is to explain the comparison in sufficient detail for independent assessment. That would require the reporting period, the source and scope of each dataset, and the adjustments made before the figures were compared.
Any claim of tax recovery should also distinguish between additional assessments issued, amounts disputed and money actually collected.
Export and import records describe opposite sides of international trade. Comparing them can identify transactions or categories of goods that warrant closer examination.
But totals must first be comparable. Relevant questions include whether they cover the same period, destinations and goods, and how they account for transit shipments, re-exports and valuation.
These are matters for reconciliation, not explanations already established for the discrepancy Mohammed reportedly described.
Nor would a confirmed $5 billion difference automatically equal $5 billion in missing tax. A revenue-loss calculation would require evidence about the goods involved, their taxable values, applicable duties and taxes, exemptions and payments already made.
The rule is also not presented by KRA as a China-only requirement. Its published guidance applies generally to importers obtaining supporting documents from the country of export.