The Excisable Goods Management System (EGMS) introduced by the Kenyan government in 2013 to combat the illicit trade in tobacco products is facing enormous challenges that are hampering its implementation. Although in 2014 the EGMS led to a reduction in undeclared production volumes and a potential substitution of illicit tobacco with licit tobacco, the system's effectiveness is limited by factors such as corruption, the complexity of the system and increased costs for small businesses. Based on these findings, the government and relevant agencies should take steps to raise consumer awareness of the EGMS and support small businesses.