Tether said KPMG issued an unqualified opinion on the 2025 financial statements of Tether International, the first full audit conducted by one of the world's four largest accounting firms. The audited balance sheet shows reserves exceeding liabilities by US$6.814 billion as of December 31, 2025.
Tether CEO Paolo Ardoino said KPMG's opinion is “the best audit opinion an independent auditor can issue” and called the work “the largest inaugural audit in the history of finance.” According to him, the company has evolved into one of the most financially relevant private companies, and the audit shows that the financial infrastructure and governance have kept pace with that responsibility.
The audit comes after years of scrutiny. In 2021, the CFTC fined Tether US$41 million, concluding that during a 26-month sample, the company had sufficient reserves to back USDT on only 27.6% of days. That same year, the New York attorney general reached an US$18.5 million settlement with Tether and Bitfinex related to representations about reserves and fund movements.
US regulation under discussion
The audit comes as the United States discusses new requirements for large stablecoin issuers. The GENIUS Act and the FDIC's proposed rule for authorized issuers provide for prescribed reserves, asset segregation, liquidity risk management, monthly public disclosure, weekly confidential reports, and annual audited financial statements for issuers with more than US$50 billion in assets.
The menu of eligible reserves in the FDIC proposal includes currency, Federal Reserve balances, demand deposits, short-term Treasury securities, overnight repurchase agreements backed by Treasuries, and certain money market instruments. Gold, which Tether has been expanding in its reserves, is not on the list, nor are bitcoin and other crypto assets.
The proposal also defines a significant redemption event as requests exceeding 10% of the outstanding issuance within 24 hours. For Tether's liabilities, estimated at about US$183.6 billion in the second quarter, that would equate to approximately US$18.4 billion in outflows in a single day, a test an annual audit does not cover.
Pressure in Congress
In February, Senator Jack Reed introduced the Foreign Stablecoin Transparency Act, citing Tether and the fact that it had not completed audits for years. The proposal would require foreign stablecoin issuers to also be audited annually, closing a gap he says exists in GENIUS.
Tether describes the KPMG audit as voluntary, and nothing in the text links the timing of the audit to Reed's legislation. The completion of the work, however, does not end the discussion: a completed audit is a one-time event, while a legal audit requirement is a continuous obligation.
USDT and USAT on separate tracks
Tether maintains two products for different markets. USAT, launched in January and issued by Anchorage Digital Bank, was designed within the GENIUS framework. Global USDT remains a separate product, with about US$184.6 billion in circulation at the end of the second quarter, more than 60% of the stablecoin market.
The KPMG audit was conducted in accordance with AICPA standards, while GENIUS establishes PCAOB standards as the statutory benchmark for annual audits of large US issuers, although the FDIC's proposed rule allows unlisted entities to choose either standard. Tether's audit regime, however, differs from the recurring examination and ongoing supervision proposed by GENIUS.
The open question is whether a one-time audit will be sufficient for regulators, since USDT reserves include gold and undergo redemption stress tests that the US rule aims to monitor continuously.
