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Gusto Vendor Risk Assessment — Full Report

Before you share customer data with Gusto, your compliance team needs documented proof they can be trusted. ThirdProof investigated Gusto across 27 intelligence sources — here's what we found.

⚠ FedRAMP Status: Not found in the FedRAMP Marketplace. Vendors handling government data or CUI must be FedRAMP authorized.

Risk Tier
Tier 3Moderate Risk
SOC 2
⚠ Vendor Attested
FedRAMP
— Not Authorized
Last Assessed
Mar 25, 2026
🟢IP Reputation: Abuse score: 0%, 0 reports🟡SSL/TLS: TLSv1.3🟢Domain Age: 30.6 years🟢Infrastructure: 13 open ports, 0 CVEs
FedRAMP Status
Gusto is not listed on the FedRAMP Marketplace as of March 2026.
SOC 2 Status
Gusto has not had a SOC 2 claim detected on their trust page.
Sanctions Screening
Gusto returned no matches in OFAC SDN, EU Consolidated, and UN sanctions screening.
Risk Tier
ThirdProof assigned Gusto a Moderate Risk tier with 100% confidence across 27 intelligence sources.

24 sources queried. 100% confidence. Every Gusto investigation produces both a risk report and an auto-filled security questionnaire — no vendor follow-up required.

Get Gusto's Full Report Free →
5 free investigations|Risk report + auto-filled questionnaire|Avg. 7 minutes

Certification & Compliance Status

Security Questionnaire — Auto-Filled

43 of 133 questions answered for Gusto

Auto-filled from public evidence • 32% complete

See all answers — Start Free →

Q37

Do you have a current SOC 2 Type II report?

SOC 2 Type II: claimed_with_trust_page

Source: External Automedium confidenceEvidence: docs.gusto.com

Q38

Do you have ISO 27001 certification?

Gusto offers integration with Secureframe to streamline ISO 27001 compliance, but no direct certification claim found at gusto.com.

Source: External Automedium confidenceEvidence: gusto.com

Q41

Are you FedRAMP authorized? At what level?

Not found in FedRAMP marketplace

Source: External Automedium confidence

Q42

Are you GDPR compliant? Do you have a DPA available?

Gusto provides an Employer Data Processing Addendum (DPA) for compliance with applicable data protection laws including GDPR.

Source: External Autohigh confidenceEvidence: gusto.com

Q23

Is data encrypted at rest? What encryption standard is used (e.g., AES-256)?

Gusto explicitly states 'All data at rest is encrypted using AES-256' in AWS.

Source: External Autohigh confidenceEvidence: gusto.com

+ 2 more compliance questions answered in the full report

Every investigation produces a full PDF report plus the complete 133-question questionnaire, mapped to SOC 2, HIPAA, PCI DSS, SIG, and more.

Get Gusto's Full Report Free →
Not Listed on FedRAMP Marketplace

Verified against FedRAMP Marketplace API as of March 2026

Organizations with federal compliance requirements should verify this directly at marketplace.fedramp.gov.

Gusto is not listed on the FedRAMP Marketplace.

27 data sources queried per assessment
Reports generated in an average of 7 minutes
SHA-256 verified for audit integrity
Deterministic risk scoring — no AI guesswork
3Tier

Moderate Risk

Gusto

Vendor Risk Assessment

Confidence Score100%

Based on data availability and source coverage

24

Sources Queried

24

Sources With Data

March 25, 2026

Last Assessed

Executive Summary

AI-generated analysis for Gusto

Gusto (gusto.com) is an established HR, payroll, and benefits SaaS platform assessed at Tier 3 (Moderate Risk), reflecting a mature and largely well-configured vendor with a small number of supply chain transparency and AI data governance gaps that warrant attention before full approval. Gusto demonstrates a number of meaningful positive signals across security, domain health, and operational maturity:

Key Findings

  • The domain has been active since 1995 with a continuous web presence archived since 1998, indicating a well-established vendor.
  • Domain reputation is clean across all major blacklists, Malware detection service flagged no threats, and the IP serving gusto.com carries a 0% abuse score.
  • HTTP security headers earned a B grade (75/100), with HSTS enforced and X-Frame-Options present.
  • TLS configuration uses TLS 1.3 with AES-256-GCM, a strong modern cipher suite, and the certificate is issued by Let's Encrypt with 72 days remaining.
  • Gusto's infrastructure sits behind Cloudflare CDN, providing DDoS mitigation and edge security. The 13 open ports observed are consistent with Cloudflare's shared CDN infrastructure and do not represent Gusto's direct application exposure.
  • No sanctions matches, adverse media, SEC enforcement actions, or FDIC concerns were identified.
  • Gusto claims SOC 2 compliance on their developer/integration documentation page (https://docs.gusto.com/app-integrations/docs/security-review), and a possible HITRUST directory match was detected, though neither could be independently verified from public registries.
  • Gusto recently acquired retirement plan provider Guideline in a $600M transaction, a notable strategic development suggesting continued growth investment. Three areas require attention before this vendor is approved for medium data access:
  • The subprocessor page at trust.gusto.com/subprocessors was found but contains placeholder content with zero subprocessors identified. For a payroll and HR platform handling sensitive employee data, this is a material supply chain transparency gap.
  • Gusto's AI data usage policy indicates that customer data (including AI prompts and responses) may be used for model training unless customers actively opt out. The opt-out mechanism and data retention period are not clearly documented in the policy page reviewed.
  • Certificate Transparency logs show 31 distinct Certificate Authorities issuing certificates across Gusto's 113-subdomain infrastructure, which may indicate inconsistent certificate lifecycle management across product lines. Overall, Gusto is a credible and established vendor with a strong operational security baseline. The Tier 3 rating reflects remediable gaps in supply chain documentation and AI data governance rather than fundamental security failures. Conditional approval is appropriate, subject to resolution of the identified gaps.

Independence Statement

All evidence in this report was independently sourced by ThirdProof from external data sources without vendor participation or input.

Investigation Findings

2 findings identified for Gusto

2 medium
medium

Multiple Certificate Issuers (31)

gusto.com has certificates from 31 different Certificate Authorities. This may indicate inconsistent certificate management practices.

medium

AI Model Training Requires Opt-Out

gusto.com may use customer data for AI training unless customers opt out. Review the opt-out process.

Security Strengths

26 positive signals verified

Legal Entity Actively Registered

Business Registration

Low-Confidence Sanctions Matches Only

Sanctions & Watchlist Screening

Firmographic Data Available

Company Intelligence

Domain Infrastructure Healthy

Domain Analysis

Valid SSL Certificate

Domain Analysis

13 Open Ports Detected

Infrastructure Exposure

Established Domain (30+ years)

Domain Registration

Clean domain reputation

Threat Intelligence

Notable Tech Community Presence

Tech Community Sentiment

Minimal Tech Community Discussion

Tech Community Sentiment

HTTP Security Grade: B

HTTP Security Scan

Large Certificate Footprint (113 subdomains)

Certificate Transparency

Established Web Presence (28+ years)

Web Archive History

Domain in 2 Threat Pulses

Threat Intelligence (OTX)

Clean IP Reputation

IP Reputation

Clean Safe Browsing Status

Malware & Phishing Check

Clean Website Security Scan

Website Security Scan

Trust Page Found, No Certifications Detected

Trust & Compliance Page Scan

Subprocessor Page Found (Placeholder)

Supply Chain & Subprocessor Discovery

Not Found as FDIC-Insured Institution

FDIC Institution Check

No SEC Enforcement Filings Found

SEC Filing Search

No Historical Adverse Media Found

Historical Media Search

HITRUST Directory Match — Manual Verification Required

Certification Registry Verification

SOC 2 Compliance Claimed on Trust Page

Certification Registry Verification

Third-Party AI Providers Disclosed

AI Data Usage Policy

AI Data Retention Policy Not Specified

AI Data Usage Policy

Recommended Actions

Steps to address findings for Gusto

  1. 1

    Request Gusto's current SOC 2 Type II report and a bridge letter covering the period to today — contact their security team directly or check https://trust.gusto.com, where many vendors make reports available under NDA. Ask whether the report covers the payroll and HR processing environment specifically.

  2. 2

    Obtain a complete subprocessor list from Gusto by contacting their privacy team. The published page at https://trust.gusto.com/subprocessors was not populated at time of assessment — request a current list directly and incorporate it into your vendor risk register.

  3. 3

    Clarify the scope and mechanism of Gusto's AI model training opt-out by reviewing your Data Processing Agreement (DPA) with Gusto. If processing sensitive employee data through AI features, require written confirmation that opt-out is in effect and document it. Review https://docs.gusto.com/app-integrations/docs/mcp for the current policy.

  4. 4

    Confirm TLS certificate auto-renewal is operational for gusto.com by asking Gusto's security team to confirm their certificate management process during your next vendor review cycle. This is low urgency at 72 days but should be documented.

  5. 5

    Independently verify HITRUST certification status by searching the HITRUST Alliance directory directly at https://directory.hitrustalliance.net/search?q=Gusto and confirming the listed entity matches Gusto (the payroll/HR company). If confirmed, this is a significant positive compliance signal worth documenting.

Intelligence Sources Queried

24 sources in this assessment

24of 24 sources returned data
IP Reputation
AI Data Usage Policy
Threat Intelligence (OTX)
Certification Registry Verification
Certificate Transparency
Domain Analysis
FDIC Institution Check
Business Registration
Historical Media Search
Tech Community Sentiment
Company Intelligence
Adverse Media Scan (Fallback)
HTTP Security Scan
Sanctions & Watchlist Screening
Malware & Phishing Check
SEC Filing Search
Infrastructure Exposure
SSL/TLS Analysis
Supply Chain & Subprocessor Discovery
Trust & Compliance Page Scan
Website Security Scan
Threat Intelligence
Web Archive History
Domain Registration

Data Coverage Notes

Some data sources may have had limited availability during this assessment. This does not reflect negatively on the vendor.

  • External cyber risk scoring was not available for this assessment; the infrastructure and domain evidence gathered from direct scans was used as a substitute signal.
  • Gusto's subprocessor page returned placeholder content with zero entries, meaning supply chain third-party exposure could not be assessed from published data.
  • The HITRUST directory returned a 90% confidence match for Gusto but insufficient contextual data to confirm this is the same legal entity — independent verification with Gusto or HITRUST Alliance is required before relying on this as a confirmed certification.
  • ISO 27001 certification status could not be confirmed via the IAF CertSearch registry — no certificate record was found under this name.
  • Gusto's AI data usage policy (docs.gusto.com) appears scoped to a specific MCP integration feature; comprehensive AI governance policies for the broader platform were not located and may not be publicly available.
  • AI data retention periods for third-party processing by Anthropic and Google were not specified in the available policy documentation.
183+
Vendors assessed
98%
Average confidence
<2 min
Time to report

Security & Compliance Profile

32% complete · 43/133 questions answered from public sources

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What a ThirdProof assessment covers

Sanctions Screening

Is Gusto on any OFAC, EU, or UN sanctions list? Are any officers or affiliates flagged?

Cyber Risk Assessment

What is Gusto's security posture? Threat intelligence scanning, known vulnerabilities, and security header analysis.

Business Registration

Is Gusto a legitimately registered business entity? Corporate status, jurisdiction, and officer verification.

Adverse Media Analysis

Has Gusto appeared in negative news coverage? Data breaches, lawsuits, regulatory actions, and complaints.

Domain & Infrastructure

Is Gusto's website secure? TLS configuration, DNS hygiene, security headers, and domain age analysis.

Company Intelligence

What are Gusto's firmographics? Employee count, industry classification, technology stack, and corporate structure.

Trust & Compliance Verification

Does Gusto claim SOC 2, ISO 27001, HITRUST, or FedRAMP? ThirdProof scans trust pages for certification claims and cross-references the FedRAMP public registry for independent verification.

Supply Chain & Subprocessor Discovery

Who does Gusto depend on? ThirdProof discovers subprocessors from vendor-published pages and runs sanctions screening and safe browsing checks against each one.

Regulatory & Financial Filings

Has Gusto appeared in SEC enforcement filings? Is it associated with any FDIC bank failures? ThirdProof searches regulatory databases with entity verification to confirm attribution.

Full methodology, rule engine, and AI disclosure: /methodology

Seeing this in an audit? ThirdProof lets you investigate Gusto and every other vendor in your stack — average report time: 7 minutes. Get Gusto's Full Report Free →

Frequently asked about Gusto

Is Gusto FedRAMP authorized?+
Gusto is not currently listed on the FedRAMP Marketplace as of March 2026.
Does Gusto have SOC 2 Type II?+
No SOC 2 found. Gusto rated Moderate Risk — subprocessor page incomplete. See all 4 findings →
Is Gusto on the OFAC sanctions list?+
Gusto returned no matches in ThirdProof's OFAC SDN, EU Consolidated, and UN sanctions screening as of March 2026.
What is Gusto's vendor risk tier?+
ThirdProof assigned Gusto a risk tier of Moderate Risk with 100% confidence based on assessment across 27 intelligence sources as of March 2026.
Can I get an auto-filled security questionnaire for Gusto?+
Yes. Every ThirdProof investigation of Gusto produces two deliverables: an audit-ready risk report and a 133-question security questionnaire pre-filled with evidence from 27 independent sources. The questionnaire is mapped to SIG, SOC 2, HIPAA, PCI DSS and 9 other frameworks — answered without sending Gusto a single email or waiting for a vendor response.
Is Gusto safe to use as a vendor?+
Gusto is a payroll vendor that handles employee SSN, bank account, and tax data. Safety depends on their current security posture, certification status, and how they handle your specific data. ThirdProof automates this evaluation across 27 intelligence sources — sanctions databases (OFAC, EU, UN), business registration verification, adverse media scanning, and cyber risk assessment — producing a deterministic risk tier with confidence score plus an auto-filled security questionnaire. Run a free investigation to see Gusto's full risk profile.
Does Gusto have SOC 2 certification?+
No SOC 2 found. Gusto rated Moderate Risk — subprocessor page incomplete. See all 4 findings →
Has Gusto had any data breaches?+
Data breach history is an important signal for any vendor, particularly payroll platforms like Gusto that handle employee SSN, bank account, and tax data. ThirdProof's adverse media analysis searches multiple news APIs and public records for data breaches, security incidents, lawsuits, regulatory enforcement actions, and financial distress signals. Each finding is linked to its original source with severity classification.
Is Gusto on any sanctions lists?+
Sanctions screening is standard due diligence for payroll vendors. ThirdProof screens Gusto against OFAC SDN, consolidated international sanctions lists, and PEP databases. The screening uses entity name verification to reduce false positives. If Gusto or any associated officers appear on a sanctions list, this triggers automatic escalation to the highest risk tier.
How do I assess Gusto for vendor risk?+
Assessing Gusto as a payroll vendor involves verifying SOC 2 Type II and data privacy regulations compliance, reviewing their subprocessor chain, and checking sanctions exposure. ThirdProof automates this across 27 intelligence sources in an average of 7 minutes — no questionnaires or vendor participation required. Your first 5 investigations are free.
How long does a ThirdProof assessment take?+
A ThirdProof assessment completes in an average of 7 minutes. 27 intelligence sources are queried in parallel — sanctions databases, business registries, threat intelligence feeds, certificate transparency logs, and more. The result is a deterministic risk tier with confidence score and audit-ready PDF report.
Is ThirdProof free?+
ThirdProof offers 5 free vendor assessments with no credit card required. Each assessment includes the full report — risk tier, confidence score, individual findings, executive summary, and PDF export. Paid plans start at $399/month for teams that need ongoing vendor monitoring.
Can I use a ThirdProof report as SOC 2 audit evidence?+
Yes. ThirdProof reports are designed to satisfy SOC 2 CC9.2 (vendor risk management) requirements. Each report includes SHA-256 integrity verification, methodology disclosure, source attribution for every finding, and AI content labeling. Auditors can independently verify the report's authenticity and trace each finding to its original source.
How is ThirdProof different from a security questionnaire?+
Security questionnaires require vendor participation, take weeks, and produce self-reported answers. ThirdProof queries 27 independent intelligence sources — no vendor involvement needed. Risk tiers are assigned by a deterministic rules engine (not AI opinion), and every finding links to its original source. You get an audit-ready report in an average of 7 minutes instead of waiting weeks for a questionnaire response.

Gusto is in your vendor stack. Can you prove you assessed them?

SOC 2 CC9.2, HIPAA, PCI-DSS, and CMMC all require documented vendor due diligence — not just knowing the answer, but having audit-ready evidence you verified it. Most compliance teams can't produce that documentation on demand.

ThirdProof investigates Gusto across 27 intelligence sources in an average of 7 minutes — sanctions screening, cyber posture, SOC 2 verification, FedRAMP status, and more. Every investigation produces two deliverables: an audit-ready risk report and an auto-filled security questionnaire your prospects and auditors expect to see.

✓ 5 free investigations✓ Risk report + auto-filled questionnaire✓ No credit card required✓ Average report time: 7 minutes

Replaces $600–$900 in manual compliance consulting time per vendor assessed.