To determine the thermal noise limit of graphene biotransistors, we have measured the complex impedance between the basal plane of single-layer graphene and an aqueous electrolyte. The impedance is dominated by an imaginary component but has a finite real component. Invoking the fluctuation-dissipation theorem, we determine the power spectral density of thermally driven voltage fluctuations at the graphene/electrolyte interface. The fluctuations have 1/fp dependence, with p = 0.75-0.85, and the magnitude of fluctuations scales inversely with area. Our results explain noise spectra previously measured in liquid-gated suspended graphene devices and provide realistic targets for future device performance. © 2015 American Chemical Society.