KPMG audit of Tether: What unqualified opinions mean for USDT in the EU

KPMG Audit Tether: Report released on August 13, 2026

Stability coin issuer Tether announced on August 13, 2026 that the audit firm KPMG U.S. Branch has audited its fiscal year 2025 financial statements and issued an unqualified audit report. According to the publisher, this is the first full annual audit in the company's history. For the German market, what is not mentioned in the announcement is the key: authorized service providers under the EU regulatory framework no longer hold USDT after the transition period of the Regulation on the Regulation of the Cryptographic Asset Markets, and the audit has not changed this. Legal status.

This article is an evaluative article that distinguishes the two issues. All content originating from the issuer's announcement, EU Regulation 2023/1114, the German Crypto Market Regulation Law and the German Income Tax Law has been identified and the source of the citation is indicated. Content beyond this range is marked as evaluation.

Tether accepts KPMG audit: Report content on August 13, 2026

The publisher's announcement is titled "Tether completes the largest first financial audit in history" and the release date is August 13, 2026. The announcement mentions that the audit firm is KPMG's U.S. branch, the report date is December 31, 2025, and the audit result is unqualified. According to the company's own disclosure, as of that date, reserves exceeded liabilities by US$6.814 billion.

The announcement quoted speeches from two company representatives. CEO Paolo Ardoino called this a "decisive moment for the stablecoin industry," and Chief Financial Officer Simon McWilliams said the company's accounts had been audited by a big four accounting firm. Both statements are made by the audited company on its own audit, rather than the auditor's conclusions. The announcement was posted on the publisher's news center.

News service CoinDesk reported on the same day and pointed out that USDT has a market value of more than US$180 billion. The issuer cited its issuance of $184.6 billion in the second quarter of 2026. These two figures correspond to different time points and should be regarded as a range of approximately US$180 billion to US$185 billion.

Unqualified audit: What the term means in an audit

Unqualified opinion is the most favorable outcome that an audit can produce. It demonstrates that, in the auditor's judgment, the audited accounts truly and fairly present the company's assets, financial condition and earnings in all material respects.

Equally important, this opinion does not address whether the business model is feasible, whether assets can be realized at book value in a crisis, or whether the product is suitable for specific investors. Audit opinions cover accounts for specific periods that have been closed. This is the key to judging the scope of application of the announcement.

Assurance and annual audits: What's the difference to make it news

Prior to this announcement, the issuer only issued quarterly assurance reports. As CoinDesk describes, assurance reports examine clearly defined disclosures, such as the size and composition of reserves at a given point in time. Audits comprehensively examine the books: transactions, assets, liabilities, income, cash flow and the evidence behind them.

This is where the value of news lies. Over the years, the issuer has been criticized repeatedly that a snapshot of reserves is not the same thing as an audited balance sheet. For fiscal year 2025, this gap has been closed. According to the company, the audit also involved a physical inventory, even including counting gold bars one by one; the issuer said its gold holdings exceeded 146 tons.

announcement clearly comes from the assurance report for the second quarter of 2026 rather than audited accounts: net operating profit of US$1.5 billion, reserve buffers of US$4.11 billion, and approximately 650 million users. Those who cited the data cited self-statements covering later stages rather than audit results.

Annual accounts only reflect the status of a specific date; what happens thereafter will not appear in any audit opinion.

Report date is December 31, 2025: Why annual audits are still a snapshot

Audited accounts as of December 31, 2025. The period between the date of this report and the date of release on August 13, 2026 was more than seven months, and the audit opinion did not cover the circumstances that occurred during this period. This is normal practice for every annual audit, and this case is no different from any listed company.

Why quarterly data can only partially make up for the gap

Assurance reports can still be available after the reporting date, the most recent one being in the second quarter of 2026, but their coverage is narrower. The following judgment is clearly an assessment: an audited financial year provides little explanation of the status of the accounts twelve or eighteen months later. It is unclear whether the issuer will conduct repeated audits every year, and no relevant commitments have been made in the announcement.

MiCA Article 48: Why audits cannot replace the authorization of e-currency tokens

For German investors, the trading location of stablecoins depends on European authorization law rather than the quality of the audit. Article 3, paragraph 1, item 7 of EU Regulation No. 2023/1114 defines an electronic currency token as "a cryptographic asset that claims to maintain a stable value by reference to the value of an official currency." Tokens pegged to the U.S. dollar fall within this definition.

Article 48, paragraph 1, of the Regulation stipulates who can provide such tokens within the EU. The wording is: No person may provide electronic currency tokens to the public in the EU or seek access to their transactions unless that person is the issuer of the token and "has been authorized as a credit institution or electronic money institution" and has notified the competent authority of the Cryptocurrency Asset White Paper and published it in accordance with Article 51. The full text of the regulation sets out the requirements in Title 4 in EUR-Lex.

Both conditions are regulatory in nature: authorization is granted by the competent authority, and white papers must be notified to the competent authority and published. No matter how thoroughly an audit firm works, it cannot replace any of them. This is where most reports of this audit stop.

Transition period under Article 143 of MiCA and Article 50 of KMAG: Why

Parts 3 and 4 of the Regulation (rules for asset reference tokens and electronic currency tokens) will apply in accordance with Article 149 (3) from June 30, 2024. For service providers, Article 143 (3) provides transitional arrangements: Anyone who provides services before December 30, 2024 in accordance with applicable laws at the time may continue to provide services until July 1, 2026 at the latest. The same article allows member states to shorten this period.

Germany took advantage of this option. Article 50, paragraph 2, item 3, of the Crypto Market Regulation Law stipulates that authorizations deemed to continue to be valid "expire no later than the end of December 31, 2025." As a result, for existing service providers in the German market, the transition period closed six months before the EU deadline. Any claim based on the oft-quoted mid-2026 is the wrong date for Germany.

USDT held in Germany: Where you can still keep your balance after the deadline

This leads to the practical part of this article: Where is your USDT? Three situations need to be distinguished. First, the balance is deposited at an authorized service provider in the EU, but can no longer be held in the form of USDT. Second, the balance is deposited with service providers not authorized by the EU. Third, the balance is self-managed, that is, your own wallet holds the private key.

For the first category, the question has a clear date. Payment service provider Revolut has announced that it will force the conversion of USDT balances for European users on August 31, 2026;cryptoticker.io detailed the process in its article on August 10, 2026. If you have a balance with an authorized service provider, please first check the service provider's inbox and help center to confirm if there is an expiration date. For which institutions hold EU authorizations, see Comparison of Regulated Crypto Exchanges.

For the second category, the situation is different. Unauthorized service providers are no longer allowed to provide services to German customers, and when their access rights will be closed cannot be predicted externally. This assessment is based on patterns in recent months and is not specific to any particular company.

Access to the EU market depends on official authorization, and audits cannot open this door.

Forced conversions and Article 23 of the Income Tax Act: Why forced conversions may be regarded as sale

If a service provider automatically converts your balance into another crypto asset or euros, this is by no means a tax-neutral event. Article 23, paragraph 1, item 2, of the German Income Tax Law deals with the disposal of other assets,"provided that the period between acquisition and disposal does not exceed one year." Convertions that occur during this period may trigger taxable gains or losses, even if you have not initiated it.

There are two other places in the same article that are relevant to this. If multiple units in the same foreign currency are held, they will be deemed to be obtained first and disposed first. In addition, according to paragraph 3, fifth sentence, if the total proceeds from private disposal transactions are "less than 1,000 euros" during the calendar year, the proceeds are exempt from tax. For tokens pegged to the US dollar, such gains are usually small, but may still arise from the exchange rate with the euro.

Since the forced conversion occurs without you taking any action, its time and consideration can easily be lost in the account statement. If you have a connection to a service provider, the Portfolio Tracker can record such events; see Comparison of Cryptotax Tools and Portfolio Trackers for common tools.

Self-custody of stablecoins: What can your own wallet solve and what remains unsolved

The third situation is the least eye-catching of the three. Anyone holding USDT in a self-managed wallet will not initially be affected by the service provider's removal: the regulation targets issuers and service providers, not private holdings of crypto assets.

This solves usability issues. But sooner or later, the path to converting crypto assets back into euros will go through the service provider, where the same authorization rules will take effect. Additional transactions will be generated through detours through other tokens, and each transaction will need to be evaluated separately in accordance with Section 23 of the Income Tax Act.

What cannot be confirmed in this article: Limitations of this assessment

First, open the register. The European Securities and Markets Authority maintains a register of notified white papers for electronic currency tokens. Its search interface loads content through scripts and cannot directly query this analysis. Therefore, this article does not make any statement about the current content of the register, but only relies on the text of the regulations and observable market events.

Second, the coverage of audit opinions. Whether audits will be repeated and for how long the intervals are not mentioned in the announcement. A single audit of completed financial years is two different things from the practice of continuous auditing.

Third, the number of affected investors in Germany. There is no reliable data at present, and this article has not estimated this.

Putting Tether audits in the background: What to focus on

Check where your USDT is stored. Check your service provider's inbox and help center to confirm if there is a deadline for conversion or withdrawal. Whether your service provider holds an EU authorization, see Comparison of Regulated Crypto Exchanges.

Record forced conversion. Once the service provider automatically converts your balance, please immediately record the date, amount and euro value, as this may become a taxable event under Section 23 of the Income Tax Act. For related tools, see Comparison of Cryptotax Tools and Portfolio Trackers.

Distinguish audit and authorization issues. The audit opinion covers the financial statements as at 31 December 2025; tradability in the EU is determined by Article 48 of EU Regulation 2023/1114. If you want to hold assets independently of your service provider, see Comparison of Cryptographic Wallets next.

(As of August 16, 2026. This article does not constitute investment advice. Price and fee structures may change; please confirm terms with your service provider before purchasing.)