
Gemini Dollar (GUSD) Review
Monthly CPA examinations, including an unannounced business day
of 10
Gemini Dollar scores 9.4/10, first of ten rated stablecoins. A NYDFS-chartered trust company issues it, BPM LLP examines the reserve monthly and on a random business day, and redemption is 1:1 at any time, but only for Gemini customers. Marks rest on desk research of Gemini's disclosures and the September 2026 report.
Score arithmetic
(10 + 10 + 9 + 9 + 9) / 5 = 9.4
Issuer and regulator
Gemini Trust Company, LLC; NYDFS-chartered, GUSD approved 10 Sep 2018
Attestation
BPM LLP, monthly examination plus a random day; latest report 29 Oct 2026
Reserve at 30 Sep 2026
38.38m GUSD outstanding; US$39.25m cash deposits before settlement items
Reserve banks
State Street and Western Alliance Bank, per the September 2026 report
Redemption
1 GUSD for $1 at any time, Gemini customers only
Scores
Each criterion carries equal weight. The overall score is the average of these 5 scores — (10.0 + 10.0 + 9.0 + 9.0 + 9.0) ÷ 5 = 9.4.
Pros
- Reserve transparency 10: BPM LLP reasonable-assurance examinations monthly and on a random day
- Regulatory oversight 10: issuer is a NYDFS-chartered trust company; GUSD approved September 2018
- Redemption 9: 1:1 for dollars at any time, no conversion fee, within one business day
- Custody 9: reserve segregated for GUSD; September report names State Street and Western Alliance
Cons
- Only Gemini customers can redeem with the issuer; other holders must sell on a market
- GUSD page lists Goldman Sachs and Fidelity, while the September report names other banks
- Small supply, about 38.4 million GUSD at 30 September 2026, and Ethereum only
Gemini Dollar (GUSD) scores 9.4 out of 10 in our stablecoin ratings, first of the ten coins rated. Every mark was rechecked on 1 November 2026 against Gemini's GUSD page, its user agreement, the September 2026 reserves report examined by accounting firm BPM LLP and the New York State Department of Financial Services (NYDFS) approval, and none has moved. The one place it falls short of full marks is access: only Gemini customers can redeem with the issuer. The basis is desk research; we did not buy or redeem GUSD.
How GUSD scores in stablecoins
The category uses five criteria, each marked 0 to 10 and each worth one fifth of the total, as set out in our ratings methodology.
| Criterion | What the published record shows | Mark |
|---|---|---|
| Reserve transparency | Monthly reasonable-assurance examinations by BPM LLP at month-end and on one randomly chosen business day; the September 2026 report is dated 29 October 2026 | 10 |
| Regulatory oversight | Issued by Gemini Trust Company, LLC, a limited purpose trust company chartered by NYDFS, which approved GUSD in September 2018 | 10 |
| Redemption rights | 1:1 for US dollars, stated as available "at any time", with no fee to convert; open to Gemini customers only | 9 |
| Custody & segregation | Reserve held in accounts segregated for GUSD; the September report names State Street and Western Alliance Bank | 9 |
| Backing model clarity | Fiat-reserve, stated plainly: bank deposits, government money market funds and Treasury bills of three months or less | 9 |
The arithmetic is a plain average: (10 + 10 + 9 + 9 + 9) / 5 = 47 / 5 = 9.4. No criterion is weighted more than another and no penalty is applied. No mark changed in this recheck.
Strongest criteria: the reserve report and the regulator
Reserve transparency (10)
The September 2026 reserves report shows why this is the only 10 on transparency in the category besides USDC. BPM LLP examined management's assertion under American Institute of CPAs (AICPA) attestation standards, which give reasonable assurance, not the lighter limited assurance some issuers use. It did so for two dates: 30 September and 9 September 2026, the second being the randomly chosen business day Gemini describes on its GUSD page. A date the issuer cannot pick in advance is harder to prepare for. The report gives 38,378,754.40 GUSD in circulation on 30 September against a reserve of US$39,246,582.59 in cash deposits, before settlement adjustments. Gemini's page links a report for each month from May to September 2026.
Regulatory oversight (10)
The issuer is a named, chartered entity under a named supervisor. NYDFS authorized Gemini Trust Company to issue GUSD on 10 September 2018, with conditions on full convertibility, anti-money-laundering controls and examination. BPM's report tests compliance with the reserve rules in NYDFS's June 2022 stablecoin guidance, so the monthly check is tied to the regulator's own requirements rather than to criteria the issuer set for itself.
Where it falls short of 10
Redemption rights (9)
Gemini says customers "can always redeem 1 GUSD for $1 on Gemini at any time", and its user agreement defines timely redemption as no more than one full business day. The limit is who qualifies: the agreement says "only Gemini Customers" can convert between GUSD and dollars with Gemini. A holder without an account, or with a restricted one, exits by selling on a market. This is the same customer-only model that earns USDP its 9.
Custody and segregation (9)
Under the NYDFS guidance quoted in the report, reserve assets must be segregated from the issuer's own assets and held for the benefit of holders at insured banks or approved custodians, and Gemini's 10-Q for the quarter to 30 June 2026 describes GUSD cash as restricted deposits. The mark stops at 9 for a disclosure mismatch. The GUSD page still says the cash "may be held at" State Street, Goldman Sachs or Fidelity, while the September report says the reserve is held as cash deposits at State Street and Western Alliance Bank. The report is the dated, examined document, so we treat it as current.
Backing model clarity (9)
The page states plainly what backs GUSD, and the April 2023 Gemini blog confirms that Treasury holdings are bills of three months or less. The one gap is that the page describes three permitted asset types while the latest report shows only cash, so a reader needs the monthly report to see the current mix.
What the score does not cover
- Size and liquidity. GUSD is small, at about 38.4 million tokens on 30 September 2026. Market depth is not scored.
- Peg history. Not a criterion in this category.
- Network reach. Gemini issues GUSD on Ethereum only; chain coverage is not scored.
- Contract controls. Gemini's user agreement allows tokens tied to a conduct violation to be frozen; contract powers are outside this rubric.
For checks the score leaves out, see our guide on how to assess a stablecoin.
GUSD vs Ripple USD and USD Coin
Two useful comparisons are USD Coin (USDC), second at 9.0, and Ripple USD (RLUSD), one of three coins tied on 8.8.
| Criterion | GUSD | RLUSD | USDC |
|---|---|---|---|
| Reserve transparency | 10 | 9 | 10 |
| Regulatory oversight | 10 | 10 | 10 |
| Redemption rights | 9 | 7 | 7 |
| Custody & segregation | 9 | 9 | 9 |
| Backing model clarity | 9 | 9 | 9 |
| Overall | 9.4 | 8.8 | 9.0 |
GUSD's lead over both comes mostly from redemption, where it scores two points higher, plus one point over RLUSD on transparency. All three score 10 on oversight and are level on custody and backing clarity, and GUSD and USDC share the top transparency mark.
Who the score suits
The rating fits readers who rank documented reserves and a named state regulator above size or multi-chain reach, and who have, or will open, a Gemini account so the redemption right applies to them. It says little about how easily GUSD trades away from Gemini. This is an assessment of published documents, not a recommendation to hold GUSD.
How it compares

USD Coin (USDC)
Most frequent reserve disclosure, with a named fund and custodian

Pax Dollar (USDP)
OCC-supervised issuer with KPMG-examined cash and repo reserves

PayPal USD (PYUSD)
OCC-supervised issuer with free, documented 1:1 redemption

Ripple USD (RLUSD)
NYDFS-chartered issuer with a named bank custodian

Global Dollar (USDG)
Licensed issuers in Singapore and the EU, with KPMG-examined reports

First Digital USD (FDUSD)
Monthly reserve reports listing each Treasury bill by CUSIP

Tether (USDT)
Named auditor and stated reserve mix, with published redemption fees

Sky USDS
Open on-chain swap route and live collateral totals

Ethena USDe
Plain disclosure that it is a hedged synthetic dollar, not fiat
Sources
Scored from published primary sources rather than hands-on use. Every figure above comes from one of the pages below, on the date shown. Manufacturers change prices and specifications without notice — if something here no longer matches the source, tell us and we will correct it.
- 1.BPM LLP / Gemini — GUSD Reserves Report, 30 September 2026 (issued 29 Oct 2026) — checked
- 2.Gemini — Gemini dollar (GUSD) page — checked
- 3.Gemini — Gemini Trust Company, LLC user agreement (updated 21 Aug 2026) — checked
- 4.Gemini Space Station, Inc. — Form 10-Q for the quarter ended 30 Jun 2026 (SEC EDGAR) — checked
- 5.NYDFS — approval of Gemini Dollar and Paxos Standard (10 Sep 2018) — checked
- 6.NYDFS — guidance on the issuance of US dollar-backed stablecoins (8 Jun 2022) — checked
- 7.Gemini blog — Adding more transparency to the reserves backing GUSD (5 Apr 2023) — checked
- 8.Coin Currents Daily — stablecoin ratings (criteria definitions) — checked
Frequently asked questions
Why does GUSD score 9.4?
It is the plain average of five equal marks: 10 for reserve transparency, 10 for regulatory oversight and 9 each for redemption rights, custody and segregation, and backing model clarity. They sum to 47, and 47 divided by 5 is 9.4.
What keeps GUSD from a perfect score?
Mainly access to redemption, which is limited to Gemini customers. Custody also stops at 9 because the GUSD page and the September 2026 reserves report name different banks, and backing clarity stops at 9 because the current asset mix is only visible in the monthly report.
Did anything change since the previous scoring?
No mark moved. The recheck confirmed BPM's monthly examinations through September 2026 and found that the latest report names State Street and Western Alliance Bank as reserve banks, which differs from the list on Gemini's GUSD page.
What does the September 2026 report actually show?
BPM LLP gave a reasonable-assurance opinion that Gemini's reserve met NYDFS requirements on 9 and 30 September 2026. On 30 September, 38,378,754.40 GUSD were outstanding, backed by cash deposits worth US$39,246,582.59 before settlement adjustments.
How does GUSD compare with RLUSD and USDC?
GUSD at 9.4 leads USD Coin at 9.0 and Ripple USD at 8.8. All three score 10 on oversight and 9 on custody and backing clarity; GUSD's edge comes from a 9 on redemption against 7 for both, plus a higher transparency mark than RLUSD.
Nothing here is financial advice. Editorial policy · How we score · How we're funded.