Many DPEs have already received Gold Seal Flight Instructor certificates at some point in their career, but if they have not, it is possible to have this issued based on examiner activity.

If an examiner has conducted more than 20 practical tests in a 24 month period, this is a qualifying event for the issuance of a Gold Seal Flight Instructor Certificate (most CFIs have this issued based on student pass rate activity).

This information can be found in FSIMS in FAA Order 8900.1, Volume 5, Chapter 2, Section 13 (http://fsims.faa.gov/PICDetail.aspx?docId=8900.1,Vol.5,Ch2,Sec13)

This does not eliminate the requirement to have a Ground Instructor Certificate with an advanced or instrument ground instructor rating.