The Big Four firm issued an unqualified opinion on 2025 accounts for Tether’s El Salvador issuing entity. The work was done to AICPA standards rather than the PCAOB standards the GENIUS Act sets for licensed U.S. issuers, and Tether has released neither the statements nor the opinion letter.
Tether said Thursday that KPMG U.S. issued an unqualified opinion on the financial statements of Tether International, S.A. de C.V. for the year ended Dec. 31, 2025, completing the first full financial statement audit in the company’s history.
An unqualified opinion is the cleanest verdict an auditor can deliver, and it answers the objection critics have raised against USDT for years — that no major accounting firm had ever audited the assets behind it.
But the scope is narrower than the announcement implies. KPMG examined one legal entity for one fiscal year under U.S. GAAP, and Tether has released no underlying documents. Its transparency page still lists only BDO assurance reports, with nothing from KPMG, and the announcement links to no opinion letter or set of statements.
The $476 Million Gap
Simon McWilliams, Tether’s chief financial officer, put the audited result at $6.814 billion in reserves above liabilities as of Dec. 31, 2025.
“We subjected our financial statements to the scrutiny of a Big Four audit, one of the most ambitious projects in the Company’s history,” McWilliams said, adding that the figure was “confirming the quality of the public attestation reports.”
The audited number sits $476 million above what Tether reported for the same date in its quarterly attestation. The BDO report for Dec. 31, 2025, approved by chairman Giancarlo Devasini on Jan. 30, gave total assets of $192.88 billion against total liabilities of $186.54 billion, or $6.338 billion in equity.
While Tether headlined that release “$6.3B in Excess Reserves,” the two figures rest on different frameworks. The reserves report applies IFRS recognition and measurement principles, but KPMG audited to U.S. GAAP.
Every Gold Bar
KPMG “physically counted and inspected every individual gold bar held by Tether, verifying the existence and identifying information of each bar rather than relying solely on reports from custodians or counterparties,” according to the announcement. BDO’s engagements obtain reports from a specialized provider on a sample basis.
At the audited date, precious metals accounted for $17.45 billion of reserves, bitcoin $8.43 billion and secured loans $17.04 billion.
Attestation Versus Audit
Tether’s quarterly reserves report states that it “does not represent the financial statements of the Company but discloses financial information extracted from its accounting records.”
BDO Advisory Services, the Milan firm that signs the opinions, limits its assurance to a single point in time, excludes the notes from its scope and provides no view on going concern. The reports carry no income statement and no cash flow statement, only a change in net equity table. KPMG’s work covered the balance sheet, income statement, statement of changes in equity and cash flows.
Tether has run that quarterly cycle since hiring BDO Italia in July 2022, an engagement it announced that August as “the next step in the company’s path toward a complete audit.” The same release said Tether would move to monthly reporting, which has not happened.
The 2021 CFTC order that fined Tether $41 million found the company “falsely represented that it would undergo routine, professional audits to demonstrate that it maintained ‘100% reserves at all times’ even though Tether reserves were not audited,” and that reserves fully backed USDT on only 27.6% of days across a 26-month sample from 2016 to 2018. Eight months earlier, the New York attorney general’s office had fined Tether and Bitfinex $18.5 million over related conduct and barred both from serving New York customers.
Tether appointed McWilliams chief financial officer in March 2025 with an explicit mandate to deliver an audit, moving Devasini to chairman. It announced the Big Four engagement on March 24 without naming the firm.
“For years, some detractors said an audit of Tether could not be completed,” CEO Paolo Ardoino said Thursday. “They said the Company refused to subject itself to the most rigorous scrutiny. We have once again proven them wrong.”
The PCAOB Gap
Ardoino said KPMG “conducted a full and thorough audit in accordance with AICPA standards.” The GENIUS Act sets a different bar. Section 4(a)(10) requires permitted payment stablecoin issuers with more than $50 billion in outstanding issuance to have annual financial statements audited by a registered public accounting firm “in accordance with all applicable auditing standards established by the Public Company Accounting Oversight Board,” and to make those statements “publicly available on the website” of the issuer.
Tether International is not a permitted issuer, and its announcement calls the audit voluntary. Section 3(b)(1) makes it unlawful to offer a payment stablecoin to U.S. persons through a service provider from July 18, 2028, three years after enactment, unless it comes from a permitted issuer or qualifies under Section 18. That section requires the Treasury secretary to find that a foreign issuer’s home regulator — for Tether, El Salvador’s CNAD, where it holds registration PSAD-0028 — runs a regime comparable to the U.S. framework, “including, in particular, the requirements under section 4(a).” Tether’s separate U.S. token, USAT, is issued by Anchorage Digital Bank and falls under the domestic regime.
Circle, the closest comparison, has published audited financial statements since before its IPO. Deloitte & Touche has audited Circle to PCAOB standards since 2023, and the FY2025 10-K treats deposits from stablecoin holders as a critical audit matter, with Deloitte independently pulling evidence from public blockchains to test the completeness of USDC outstanding.
A Thinner Cushion
USDT trades at $0.9991 with a market cap of $183.0 billion, according to CoinGecko, holding 60.8% of the $300.8 billion stablecoin market tracked by DefiLlama. USDC is second at $72.2 billion.
Tether’s equity buffer has fallen since the audited date. The June 30, 2026 report shows $187.75 billion in assets against $183.64 billion in liabilities, leaving $4.11 billion in equity, down from an all-time high of $8.23 billion at the end of March. Bitcoin holdings dropped to $5.80 billion from $8.43 billion over the first half, while precious metals rose to $18.84 billion after Tether International bought about 27.1 metric tonnes of gold, with prices down 14.1% in the second quarter by the company’s own accounting.
Tether announced $1.04 billion in Q1 profit and $1.5 billion in Q2 net operating profit, its own non-standard measure. The change in net equity table in the June report puts the financial result for the six months to June 30 at negative $3.171 billion, offset by $943 million in net capital movements.
S&P Global Ratings cut USDT to 5, the weakest score on its stability scale, on Nov. 26, citing the share of reserves in higher-risk assets. Ardoino responded by attacking what he called “the traditional finance propaganda machine.”
“People may describe this as the end of a long journey, but we see it as the beginning of the next one,” Ardoino said Thursday, adding that “the proof of that stability is no longer just a Tether promise; it’s a signed opinion.”
Tether did not say whether it intends to publish the audited statements.
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