
Is THIKA ready to be KENYA'S SIXTH CITY ?
Abstract
The Urban Areas and Cities Act (No. 13 of 2011, as amended) sets out the statutory framework governing the classification of urban areas in Kenya, including the criteria a municipality must satisfy to be conferred city status. Among the eight statutory tests referenced by the committee are population thresholds, demonstrated revenue-generating capacity, financial management practices, public infrastructure, and waste management standards. The Act operationalises Article 6 and the Fourth Schedule of the Constitution of Kenya 2010, which allocate urban planning and county government functions between national and county levels, and it is administered through the Senate's devolution oversight function under Article 96.
Conferment itself is a presidential act. Once the Senate adopts a committee report and the House votes, the President issues a charter under the Act, formally elevating the municipality's status. This is the same route Nakuru followed in 2021, becoming Kenya's fourth city roughly thirteen months after the Senate received the county's application, and Eldoret followed in 2024 as the fifth.
Introduction
The Senate committee's report tabled this month recommends Thika for city status, the sixth such conferment since counties began qualifying under the Urban Areas and Cities Act. On its face, this is a routine step in Kenya's urbanisation trajectory, following Nakuru in 2021 and Eldoret in 2024. Beneath that framing sits a financial record with a wide, unreconciled variance between revenue collected and expenditure verified, and a population figure disputed by the very governor whose county stands to benefit from conferment.
The committee has acknowledged these gaps in its own report rather than concealing them. It has asked for reconciliation and imposed a 90-day post-conferment reporting obligation on Kiambu Governor Kimani Wamatangi.
The financial verification dimension sits within a separate but connected framework. The Office of the Auditor-General is constitutionally mandated under Article 229 to audit and report on the accounts of all county governments and public entities. The Public Finance Management Act, 2012 requires county governments to maintain auditable financial records and, since a National Treasury circular took effect in the 2021/22 financial year, requires standalone reporting for municipal entities rather than consolidation into county executive accounts. Before that circular, municipalities' finances were folded into the broader county accounts, which Kiambu County cites as the explanation for the pre-2021/22 reporting gap in Thika's case.
Background
Auditor-General records show Thika collected KSh6.47 billion in revenue between 2018/19 and 2024/25 but only KSh272.68 million in verified expenditure, a gap Kiambu County attributes to consolidated accounting practices predating a 2021/22 Treasury reporting circular. Population compliance rests on 2019 census data and a KNBS figure of 284,727, while Kiambu's governor separately told the committee the true population exceeds 500,000. The committee has proceeded despite these discrepancies, mirroring its own 2023 treatment of Eldoret.
Analysis
The Urban Areas and Cities Act sets statutory tests, but the committee's own report shows those tests being applied against contested and partially unverifiable evidence. The financial capacity test was satisfied on the basis that Thika generated substantial revenue, a KSh6.47 billion figure over seven years, without a matching expenditure record for three of those years and with only a 6.7% expenditure-to-revenue ratio in the four years that were reported. A revenue-generation test that does not require a matching, verified expenditure picture measures collection capacity, not financial health or prudent management, both of which are separate statutory criteria under the Act. Treating revenue capacity as satisfied while expenditure remains substantially unverified narrows the practical scope of the "prudent financial management" test to something closer to a formality.
The population test raises a distinct legal question. The committee relied on the 2019 census figure of 279,429 and a KNBS-supplied figure of 284,727, both comfortably above the 250,000 threshold. Governor Wamatangi's submission of "over 500,000" was not adopted, nor was it reconciled against the official figures in the report as tabled. Where a state officer's own submission diverges this significantly from the statistical basis of a statutory determination, and the committee proceeds without addressing the divergence, the eventual charter becomes vulnerable to a future challenge on the adequacy of the population finding, particularly if a similarly situated county contests its own conferment timeline or a rejected application on comparative grounds.
For businesses already embedded in Thika, including Bidco Africa, Broadways Bakery, Kenya Vehicle Manufacturers, and Del Monte Kenya, city status carries practical operational consequences beyond symbolism: revised municipal rates and levy structures typically follow city conferment, along with changed planning and zoning authority. The existing infrastructure deficit is material regardless of the vote's outcome. A daily water supply shortfall of 19,000 cubic metres against 62,000 cubic metres of demand, and a solid waste collection rate of 60% against 140 tonnes generated daily, represent operating constraints that city status alone does not resolve and that any commercial or industrial operator should factor into medium-term planning independent of the political outcome.
Conclusion
Thika's likely elevation to city status is not in serious doubt at this stage, but the process producing that outcome now has a documented pattern: financial and demographic gaps get named, not resolved, before conferment proceeds. That pattern, repeated across Eldoret and Thika, matters more than the individual outcome in either case. It signals to every county preparing a similar application, and to every institution planning around Kenya's expanding city map, that the Urban Areas and Cities Act's verification tests currently function as a disclosure requirement rather than a hard compliance gate. Decision-makers should plan accordingly, treating official municipal statistics as provisional until independently reconciled, and watching whether Kiambu County's 90-day reporting obligation becomes the first real test of enforcement under this framework.
Citations
- 1.Constitution of Kenya, 2010, Article 6 and the Fourth Schedule (division of national and county government functions).
- 2.Constitution of Kenya, 2010, Article 96 (Senate's role in representing and protecting county interests).
- 3.Constitution of Kenya, 2010, Article 229 (Office of the Auditor-General mandate).
- 4.Urban Areas and Cities Act, No. 13 of 2011 (as amended).
- 5.Public Finance Management Act, No. 18 of 2012.
- 6.National Treasury Circular mandating standalone municipal financial reporting, effective Financial Year 2021/22.
- 7.Senate Standing Committee on Devolution and Intergovernmental Relations, Report on Thika Municipality's Application for City Status, tabled July 2026.
- 8.Office of the Auditor-General, Financial Records Review of Thika Municipality, Financial Years 2018/19 to 2024/25.
- 9.Senate Standing Committee on Devolution and Intergovernmental Relations, Report on Eldoret Municipality's Application for City Status, 2023.
- 10.Kenya National Bureau of Statistics (KNBS), 2019 Kenya Population and Housing Census, Kiambu County data.
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