Notifying BRS of director changes
Which BRS forms cover a new director, changed particulars, a residential address and a director leaving, plus the iTax and client-record follow-up.
By Achekam · · 5 min read · For Accountants & audit firms in Kenya
Board changes rarely arrive as tidy instructions. A client mentions in passing that a co-founder has stepped back, that a new investor's nominee joined the board last month, or that one director has moved house and changed her name on marriage. Each of those is a filing with the Registrar, and each tends to surface only when someone pulls a CR12 for a bank and finds it out of date.
For a firm that keeps a Kenyan client's statutory records, the job is to match each event to the right Business Registration Service form, collect what the form needs, and then make sure the change reaches the other places the director's details live. This article goes through the forms, the follow-up on the tax side, and how to keep the firm's own records in step.
The four director forms
BRS lists four notices for directors under the Companies Act, 2015. Three of them, CR7, CR8 and CR9, cite section 138.
| Event | Form | Typical trigger |
|---|---|---|
| A director is appointed | CR6 | A new board member, an investor's nominee, a replacement after a resignation |
| A director's particulars change | CR7 | Any change to a director's recorded details, such as a new surname |
| A director's residential address | CR8 | A director moves house |
| A director ceases to hold office | CR9 | Resignation, removal or death |
Because each event has its own form, a resignation followed by a replacement involves two notices: CR9 for the person leaving and CR6 for the newcomer. BRS publishes the official Companies Registry forms, from CR1 onwards, for incorporating a company and notifying changes to directors and other particulars, and that page is the place to confirm the current version of each form before filing.
Check the time allowed for each notice in the Act and in BRS's guidance rather than relying on memory, and file soon after the board acts.
What it costs and how long it takes
BRS's Companies Registry fee schedule lists a fee of Kshs 550 for notifying a change in directors' particulars on form CR7, with a stated turnaround of 2 days. The same fee applies to a change of company address or location on form CR 16, which BRS lists at 1 day. The schedule page is undated, so check it on eCitizen when filing.
Those figures matter less for the fee than for planning: a client who needs an updated CR12 for a loan next week can be told when to expect it.
The tax side: directors on iTax
Company records and tax records overlap where directors are concerned. KRA's non-individual PIN form asks for the company's basic information in section A, obligation details in section B and details of directors and associates in section D, with agent details in section E optional.
BRS, for its part, says the directors and shareholders of a new private limited company must be registered on the iTax platform. When an existing client appoints a new director, it is sensible to collect that person's KRA PIN at the same time as the appointment papers, and to check whether the company's KRA records still show the people who actually run it. A change of company address on the BRS side may also need to be reflected with KRA; that is covered in updating VAT and business details with KRA.
Ownership may change too
A new director sometimes arrives with a new shareholder, and a departing founder may be selling shares. If the board change comes with a change in who owns or controls the company, the beneficial ownership register and the matching BRS forms need attention as well; see identifying beneficial owners and filing BOF1.
Collecting what you need through Achekam
The slow part of any director filing is getting the papers. Staff can create, send and track requests to clients for documents, answers and confirmations in one RFI console, whichever screen the request started from.
A request for a new appointment might list:
- The board resolution or minutes appointing the director, with the date.
- The director's ID or passport copy.
- The director's KRA PIN.
- The director's residential address and contact details.
- The director's written consent to act, if the firm's process asks for one.
For a cessation, the list is shorter: the resignation letter or removal resolution and its date. Because each item is tracked, the firm can see at a glance which appointment is stuck waiting on a single document.
Keeping the client record up to date
Once the filing is lodged, update the firm's own records. A firm keeps its client directory on Achekam, adding clients through a step-by-step wizard or a CSV import, and editing or archiving them later. Staff can then open any client's Client 360 record, which brings together the client's services, contacts, timeline and profile.
Update the contacts so that the new director is there and the departed one is marked as no longer acting. That matters beyond tidiness: engagement letters, management representation letters and signing instructions should go to people who are currently directors.
One limit is worth knowing. Some sub-lists in the client directory that are edited in place, including statutory deadlines, accrued hours and KYC fields, still live only in the browser, according to the store's own header. Record the director change and its filing date somewhere that sits on the server, such as the client's contacts and timeline, rather than relying on those in-place lists.
A checklist after every board change
- Identify each event separately: appointment, change of particulars, address, cessation.
- Match each to CR6, CR7, CR8 or CR9.
- Request the papers through one tracked request.
- File with BRS and save the confirmation in the client's folder.
- Collect the new director's KRA PIN and check the company's KRA details.
- Consider whether beneficial ownership has changed.
- Update the client's contacts in Achekam and note the filing in the timeline.
Next step
At the next annual review for each company client, pull a fresh CR12 and compare it with the directors in the firm's records. Any mismatch is a filing that was missed. The recurring filings that sit around these one-off events are listed in company secretarial deadlines in Kenya.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
