Gemini: crypto exchanges rating breakdown

Custody of funds: 8/10

Proof-of-reserves: does it exist, who attests it, does it include liabilities (a PoR without liabilities is close to meaningless), how often. Insurance fund: size, is the address public, and has it ever actually paid out. Hack history — and above all whether users were made whole. Licences by jurisdiction, and the enforcement record behind them. Every claim here is sourced to a primary document: a regulator’s register, a court filing, or the venue’s own published proof.

Scored 8 of 10 against a category median of 5, which places it 3rd of 28 among centralised exchanges on this criterion. At a 40% weight that is 1.20 points above the median contribution of the weighted total. The best score in the category is 9, the worst 1.

No proof of reserves — not a weak one, none at all. The words “proof of reserve” and “Merkle” appear zero times in its annual report. What it has instead is unusually solid for this sector: audited financial statements, SOC 1 and SOC 2 Type 2 examinations by Deloitte, a New York trust charter, and a public listing with SEC filings. Stronger than an assets-only proof in some ways — but it gives you no way to check your own balance yourself. Do not let anyone tell you Gemini “has proof of reserves”. Note also that the monthly attestations it does publish cover its stablecoin’s reserves, not your exchange balance. Real theft insurance, and confirmed inside an audited SEC filing rather than a blog post: $25m of crime cover for the hot wallet and $100m of specie cover for cold storage. It excludes account takeover and user-initiated fraud — read that twice. The “$200m” figure still circulating is stale; the audited number is $125m.

True cost of trading: 3/10

Measured by us, not read off a fee page. We walk the live order book and fill $1,000 / $10,000 / $100,000 of BTC/USDT, then add the venue’s published taker fee. That sum — fee + spread + realised slippage — is the effective cost. Separately: the markup on network withdrawal fees, and the hidden spread inside “convert” / “buy in one click” flows.

Scored 3 of 10 against a category median of 6, which places it 25th of 28 among centralised exchanges on this criterion. At a 16% weight that is 0.48 points below the median contribution of the weighted total. The best score in the category is 10, the worst 1.

Liquidity and execution: 3/10

Order-book depth within ±0.1% and ±0.5% of mid, measured from the live book. Uptime over 12 months from the status page. Behaviour under stress: were there outages on days the market moved more than 5%.

Scored 3 of 10 against a category median of 6, which places it 24th of 28 among centralised exchanges on this criterion. At a 11% weight that is 0.33 points below the median contribution of the weighted total. The best score in the category is 10, the worst 1.

Assets and networks: 4/10

Number of pairs, adjusted for quality: the share of listings delisted within a year. Which networks are actually supported for deposit and withdrawal — not merely “supports USDT”.

Scored 4 of 10 against a category median of 6.5, which places it 24th of 28 among centralised exchanges on this criterion. At a 9% weight that is 0.23 points below the median contribution of the weighted total. The best score in the category is 10, the worst 1.

100+ assets by its own count; it does not publish a pair count

Fiat on/off ramp: 9/10

Which methods are actually available per country, their fees, and their limits per verification tier — read from the venue’s published terms and cited. Where a venue does not publish this, that opacity is itself the finding, and it scores accordingly.

Scored 9 of 10 against a category median of 5.5, which places it 2nd of 28 among centralised exchanges on this criterion. At a 11% weight that is 0.39 points above the median contribution of the weighted total. The best score in the category is 10, the worst 1.

Genuinely strong: USD (ACH and wire), GBP (Faster Payments), EUR (SEPA) and SGD — real rails in and out, not a card gateway.

KYC and access: 7/10

Verification tiers and their limits, what is genuinely usable without verification, and the country deny-list — from the venue’s published policy, cited. A venue that will not tell you your withdrawal ceiling before you sign up is marked down for it.

Scored 7 of 10 against a category median of 6, which places it 8th of 28 among centralised exchanges on this criterion. At a 8% weight that is 0.08 points above the median contribution of the weighted total. The best score in the category is 9, the worst 1.

Verification requirements are public, but there is no tier table and the numeric limits are not published — they appear only once you are inside. United States: All 50 states plus DC and Puerto Rico. Gemini Trust Company is a New York trust company chartered by NYDFS. European Union: MiCA CASP — MFSA (Malta), held. Licensed in August 2025 — and then left anyway. Gemini closed every customer account in the EEA on 6 April 2026. The licence is real; the access is gone. A green tick here would be a lie.

Product, API and docs: 8/10

API documentation quality, whether rate limits are documented, whether a public status page with uptime history exists, and the API response latency we measured ourselves while pulling the order book.

Scored 8 of 10 against a category median of 5.5, which places it 3rd of 28 among centralised exchanges on this criterion. At a 5% weight that is 0.13 points above the median contribution of the weighted total. The best score in the category is 9, the worst 4.

Documented API and rate limits, and a status page that actually publishes uptime — which is how we can tell you it showed 97.4% over 90 days. For an exchange, that is a weak number, and it is to Gemini’s credit that it is visible at all.