Three reports signed in October 2026
How much does a reserve attestation actually tell you? Start with the newest reports for three dollar coins, all signed in October 2026. Accounting firm Deloitte & Touche signed Circle’s USDC report on October 26, finding that at 11:59 pm UTC on September 30, 73,878,861,314 USDC were in circulation against reserves with a fair value of $73,956,687,701.
| Coin | Firm and standard | Dates tested | Result on September 30, 2026 |
|---|---|---|---|
| USDC (Circle) | Deloitte & Touche, AICPA attestation standards | September 4 and 30 | Reserves of $73.96 billion against 73.88 billion tokens |
| PYUSD (Paxos) | KPMG, AICPA attestation standards | September 17 and 30 | Reserves of $2.755 billion against 2.748 billion tokens |
| USDT (Tether) | BDO in Milan, ISAE 3000 (Revised) | September 30 | Assets of $191.45 billion against liabilities of $183.50 billion |
KPMG signed the PYUSD report for Paxos on October 23, and BDO signed Tether’s quarterly report on October 30. Tether’s line is built differently. It sets the issuing company’s total assets against all of its liabilities, leaving net equity of $7,954,630,470, where the other two compare reserves with the tokens outstanding.
Two dates a month, not every day
The dates are the catch. Circle and Paxos each test one date earlier in the month and one at its end, while Tether tests one date per quarter. BDO’s report says so plainly: “The reporting date is limited to a point in time as of 30 September 2026. We did not perform procedures or provide any assurance at any other date or time in this report.”
Calling such a report an audit is the common slip, and US law keeps the two apart. The GENIUS Act requires a registered public accounting firm to examine each issuer’s reserve report every month, while a full audit of annual financial statements, under PCAOB standards, applies only to issuers with more than $50 billion outstanding that do not already report to the SEC.
Exchanges run a related but different check on customer balances, known as proof of reserves.
What the rules will require
The Office of the Comptroller of the Currency set the US timing in a final rule of October 23, 2026. By noon on the last day of each month, an issuer it supervises must publish its reserves as of noon on the last day of the previous month, along with the accountant’s examination report. Its chief executive and chief financial officer certify that report to the OCC monthly.
The EU tests less often. Article 36 of MiCA requires issuers of asset-referenced tokens to commission an independent audit of their reserve every six months. Article 58 extends that duty to electronic money institutions that issue a significant e-money token, with the six-month clock starting from the classification decision.
How to read one
Open the issuer’s transparency page and check the firm’s name, the dates tested, the standard used and what is being compared with what. Circle’s transparency page says a Big Four firm provides “monthly third-party assurance” under AICPA standards. Paxos names KPMG for reports posted since February 28, 2025, and WithumSmith+Brown before that, and its page describes the work of both firms as an examination under AICPA attestation standards.
Expect a lag. Deloitte signed 26 days after its September 30 test date, and KPMG 23 days after the same date. From January 18, 2027, when the OCC rule takes effect, each issuer the OCC supervises will have to post a freshly examined report every month.