Payment Rails CROPS Dashboard
Unaudited, unvetted, experimental. Do not use as a reference. AI-researched ratings that may be wrong; not advice or a statement of fact about any provider. Full disclaimer
Pending review. 1150 of 1150 ratings not yet checked by a human. Do not rely on unreviewed ratings.

HesabPay

incumbentOff-chain No public chain settlementhesab.com

Incumbent rails have no public chain settlement and no public code. They are scored with the same rubric as every other row. Their low ratings show the verifiability gap between rails whose behaviour can be inspected and rails whose behaviour must be trusted; that gap is the point of the comparison, not a claim that the incumbent is unsafe.

At a glance

Category
Incumbent baseline
Chain
Off-chainOff-chain
CROPS tally
0 of 23 hold up · 11 no evidence
Security audits
None published
Offered
Not on file
Last edited
2026-10-13 · History
  1. Censorship Resistance0 FailsWeakest: Admin pause or freeze powers; Settle without the provider; Reliance on hosted services; Token and chain freeze risks disclosed
  2. Open0 FailsWeakest: Contracts verified onchain; Whole stack published; Can be self-hosted
  3. Free0 FailsWeakest: Open-source licences; Protection against relicensing; No proprietary dependencies
  4. Privacy0 FailsWeakest: Data collected beyond payment; Payments linkable onchain; Endpoints can be changed
  5. Security0 FailsWeakest: Who can upgrade the code; Token approval scope; Funds safe if provider disappears; Secrets and webhook handling; Audits and bug bounty

Where it is offered

No first-party country statement is on file for this provider. See the Countries index.

Censorship Resistance

Who can block valid use, and can users route around them?

0 FailsPillar rating: weakest of 5
0 of 5 Partial or better · 1 no evidence

What would raise this pillar

Admin pause or freeze powers

Can any privileged role stop, freeze, or block payments through the settlement contracts, and how is that role constrained? C1

0 Fails

Sets the pillar ratingBest evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

HesabPay can suspend or terminate individual accounts, including on government order, and the terms state no notice period or appeal path. There are no settlement contracts; the role holder is HesabPay itself. Judgment call: anchor 0 ("can target individual addresses with no notice") applied to account-level suspension in a custodial ledger.

Evidence (1)1 documented
  1. Documented

    Terms and Conditions (effective 2026-04-06) s5.1: failure to provide government ID 'may result in account suspension or termination'; s7 lists termination grounds including 'Court or government orders mandating termination'. No notice period is stated.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Settle without the provider

Can a payer or payee complete settlement by calling the public contracts directly, without the provider's API, signer, or relayer? C2

0 Fails

Sets the pillar ratingBest evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

Settlement is a book entry on HesabPay's custodial ledger. The terms describe no path for a payer or payee to settle without HesabPay's app, USSD service, or API.

Evidence (1)1 documented
  1. Documented

    Terms s2.3: 'HesabPay functions as a custodial wallet service that holds user funds at a 1:1 ratio in the banking system'; s3.1 transfers run between HesabPay accounts, bank accounts, or cash-out agents.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Reliance on hosted services

Does the payment flow require a relayer, paymaster, bundler, or API that only the provider runs? C3

0 Fails

Sets the pillar ratingBest evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

Every payment flow requires HesabPay's hosted services. No intermediary code is public (see notes for the search), so the dependency is closed and single-vendor.

Evidence (1)1 documented
  1. Documented

    Terms s1.2, s2.7, s2.8: every listed flow (app, USSD *580#, HesabPOS, REST API and WooCommerce plugins at developers.hesab.com) runs through HesabPay-operated services; s6 reserves all IP to HesabPay, Inc.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Neutral settlement, disclosed filtering

Is the settlement layer free of address or geographic filtering, and is any filtering at the edge disclosed and avoidable? C4

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

HesabPay discloses, in its terms and privacy policy only, that it monitors transactions for AML and fraud, applies jurisdiction-based limits, and terminates accounts on court or government order. It names no screening list. There is no separate settlement layer: filtering and settlement both happen in HesabPay's closed ledger, so the neutrality of settlement cannot be shown from code, and no direct path bypasses the filtering (C2 = 0). Judgment call: anchor 1 ("edge filtering disclosed in docs only, or the neutrality of the settlement layer cannot be shown from code") rather than 0, because the filtering read is disclosed and nothing read shows undisclosed filtering; the ledger is closed, so undisclosed filtering cannot be ruled out either, and a trace or internal document showing it would lower this to 0. Documented tier caps the cell at 1.

Evidence (2)2 documented
  1. Documented

    Privacy Policy s2 'Identity Verification': data is used for KYC and AML compliance 'as required by Da Afghanistan Bank and applicable laws'; s4.2 lists automated fraud detection and real-time transaction monitoring.

    hesab.com/privacy

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

  2. Documented

    Terms s7 lists 'Court or government orders mandating termination' as a termination ground; s3.1 says transaction limits may apply based on jurisdictional regulations; s5.2 says suspicious activities are referred to the authorities.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Token and chain freeze risks disclosed

Are the tokens and chains the rail depends on enumerated, with their issuers' freeze powers and sequencer assumptions stated to payees? C5

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Open

Is the whole stack visible?

0 FailsPillar rating: weakest of 4
0 of 4 Partial or better · 2 no evidence

What would raise this pillar

Contracts verified onchain

Does the deployed bytecode match public source, and can a third party rebuild it? O1

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Whole stack published

Are the SDK, frontend, backend or API, indexer, and deploy scripts all public? O2

0 Fails

Sets the pillar ratingBest evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No part of the stack is public. GitHub searches found no HesabPay-owned organisation or repository (search log in docs/research/hesabpay.md), and the terms reserve all IP.

Evidence (1)1 documented
  1. Documented

    Terms s6: all intellectual property in the application and website is owned by HesabPay, Inc.; users get 'a limited, non-transferable license for personal, authorized use'.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Can be self-hosted

Can a stranger reach a working deployment from the README? O3

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Interfaces and data export

Are ABIs, event schemas, an API schema, and a payee data export in a non-proprietary format all in the repo? O4

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

A REST API and a statement export are documented. Nothing is versioned in a public repo, and the export format is not named. Judgment call: the API reference at developers.hesab.com is a client-rendered app whose docs routes appear to sit behind login, so this score rests on the terms and policy text, not on a published API schema.

Evidence (2)2 documented
  1. Documented

    Terms s2.8: 'HesabPay provides RESTful APIs, WooCommerce/WordPress plugins, and split payment capabilities', governed by a Developer Agreement at developers.hesab.com; s2.2 statements are downloadable.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

  2. Documented

    Privacy Policy s5 'Data Portability': users may download transaction history and account statements 'in standard formats'.

    hesab.com/privacy

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Free

Does the license actually let a third party fork, modify, and run it?

0 FailsPillar rating: weakest of 3
0 of 3 Partial or better · 2 no evidence

What would raise this pillar

Open-source licences

Does every repository needed to run the product carry an OSI-approved license? F1

0 Fails

Sets the pillar ratingBest evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

The product is proprietary. No public repository exists, and the only license offered is a limited, non-transferable use license, so a third party cannot fork or run it.

Evidence (1)1 documented
  1. Documented

    Terms s6: 'Users are granted a limited, non-transferable license for personal, authorized use. Unauthorized use is strictly prohibited.'

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Protection against relicensing

Can the provider unilaterally relicense future versions, and has it committed not to? F2

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

No proprietary dependencies

Does a production deployment need a proprietary plugin or hosted-only service? F3

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Privacy

What can an observer learn, and did the user knowingly choose it?

0 FailsPillar rating: weakest of 5
0 of 5 Partial or better · 2 no evidence

What would raise this pillar

Tracking and analytics

Do the SDK, widget, or frontend ship analytics, telemetry, error reporting, or fingerprinting? P1

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

Google Analytics loads by default on hesab.com and the privacy policy discloses analytics in general terms without naming Google. Google reCAPTCHA also loads on the page and is not named in the policy. The mobile app and web.hesab.com were not inspected at a pinned source, so the score covers the website plus the policy. Judgment call: 1 (present, on by default, disclosed) rather than 0, because analytics collection is disclosed even though the vendor is not named.

Evidence (2)2 documented
  1. Documented

    Reproduction: curl -sL https://hesab.com | grep -o 'googletagmanager.com/gtag/js?id=[A-Z0-9-]*' returns G-GMHMD0CKK3 (Google Analytics, loaded unconditionally); the same page preloads google.com/recaptcha/api.js. Run 2026-10-07.

    hesab.com

    checked 2026-10-07

  2. Documented

    Privacy Policy s6: the website uses 'analytics cookies to understand visitor behavior'; s1.2 lists automatically collected device identifiers, IP address and app usage patterns.

    hesab.com/privacy

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Data collected beyond payment

Does the flow collect anything beyond addresses, amounts, token, and chain? P2

0 Fails

Sets the pillar ratingBest evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

KYC collection (name, date of birth, national ID or passport) is disclosed in the privacy policy with a stated legal basis (Da Afghanistan Bank KYC/AML rules); on its own that would score 1, since the basis is disclosed in a policy, not in code or a versioned repo document. But the same policy discloses automatic collection of app usage data (features accessed, transaction frequency, session duration) for product improvement, which goes beyond the stated legal requirement, and the updated anchor 0 covers "collection beyond the stated legal requirement". Score lowered from 1 to 0 on HesabPay's own policy text. Judgment call: usage data is read as collection by the payment flow because the policy ties it to the app that runs payments; device and location data for fraud prevention and the agent finder were not counted against the score.

Evidence (3)3 documented
  1. Documented

    Privacy Policy s1.1: registration collects full name, phone, email, date of birth, and national ID or passport for KYC; s1.2 collects device identifiers, IP, usage data and location; s1.3 adds data from identity-verification services and government databases. s2 states the KYC basis: AML/KYC regulations 'as required by Da Afghanistan Bank and applicable laws'.

    hesab.com/privacy

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

  2. Documented

    Privacy Policy s1.2 'Usage Data': app usage patterns, features accessed, transaction frequency, session duration and interaction with notifications are collected automatically; s2 'Improvement' uses them to improve app performance and develop new features, a purpose with no stated legal basis.

    hesab.com/privacy

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

  3. Documented

    Terms s1.1: account creation needs only a mobile number; s5.1: HesabPay 'may require' government-issued ID, and refusal may lead to suspension.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Payments linkable onchain

What do calldata and events reveal about who paid whom for what? P3

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Third parties in the payment flow

Which third parties see a request during a payment, and can they be swapped out? P4

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

Third parties see transaction data and are disclosed only in the policy. Most are named by category, a few by name. Nothing shows whether they can be swapped.

Evidence (1)1 documented
  1. Documented

    Privacy Policy s3 names recipients: banking partners, card networks (Visa, Mastercard, American Express), payment processors, Duffel and other booking/delivery partners, AI language-model providers, regulators, and agents/merchants.

    hesab.com/privacy

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Endpoints can be changed

Can RPC and indexer URLs be changed, and is the indexer code public? P5

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Security

Who can cause loss, lock users in, or change the rules?

0 FailsPillar rating: weakest of 6
0 of 6 Partial or better · 4 no evidence

What would raise this pillar

Who holds funds in transit

Who holds funds between payer and payee, and can the provider redirect them? S1

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

HesabPay holds funds in flight and at rest, and the terms disclose this. The terms limit HesabPay's use of those funds to cases with user consent; no onchain artifact confirms this.

Evidence (1)1 documented
  1. Documented

    Terms s2.3: custodial wallet holding user funds 1:1 in the banking system; HesabPay 'does not invest, transfer, or use your funds ... without your explicit consent'; s3.4 reversals are run by HesabPay's team with recipient consent.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Who can upgrade the code

Who can change the contract code, and with how much notice? S2

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Token approval scope

How large an allowance does the SDK ask users to grant, and for how long? S3

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Funds safe if provider disappears Derived

If the provider disappears tomorrow, do payees keep their funds and the ability to keep settling? S4

0 Fails

Sets the pillar ratingBest evidence: DocumentedChecked 2026-10-19 today

UnreviewedAssessed by AI research agent (seed), 2026-10-07

Derived. S1 = 1 (provider custody), C2 = 0 (no direct settlement), C3 = 0 (closed single-vendor services), O3 unknown (no public code to self-host). If HesabPay stopped operating, both funds and the ability to settle would depend on HesabPay and its partner banks.

Evidence (1)1 documented
  1. Documented

    Terms s2.3 (custodial wallet) and s3.1 (all transfers via HesabPay accounts, banks or agents); no exit path independent of HesabPay is described.

    hesab.com/terms

    checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

Secrets and webhook handling

Are secrets kept out of client bundles and are webhooks signed and verified? S5

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Audits and bug bounty

Has the code been audited at a pinned commit, were findings fixed traceably, and is there a live bounty? S6

No evidence

Sets the pillar rating

UnreviewedAssessed by AI research agent (seed), 2026-10-07

No checkable evidence settles this yet, so it counts as 0.

Security audits 0

Published audits and similar reviews of this provider's code, newest first. Context for the Audits and bug bounty rating, which scores them; this list does not change any rating, and an audit of older code says little about what is deployed now.

No published audit report was found.

Compiled from: hesab.com (home, privacy policy, terms, help and docs pages; the privacy policy mentions "blockchain-secured" fraud detection but names no audit), developers.hesab.com, web searches for HesabPay security audits, penetration tests and certifications, and GitHub. No published code audit, penetration test or SOC/ISO report was found. HesabPay is a closed custodial ledger with no public contract or repository in the payment path. Checked 2026-10-13. Only published reports are listed; private audits a provider mentions without a report are not.

Operational and procurement

Facts an institution's procurement, finance and security functions ask for. Separate from the CROPS ratings and never scored.

Group A: operational facts. Group B: 45 due-diligence controls derived from a UN agency's vendor requirements: 7 evidenced, 1 attested, 0 absent, 0 not applicable, 37 unknown. "Not applicable" means there is no operator to hold the control: it falls to whoever deploys the rail. How to read this.

Group A: operational facts

Fees

Evidenced
ComponentPaid byAmountBasis
providerpayermonthly maintenance, 15 points (active accounts) or AFN 15 (inactive accounts)Terms s4.1; HesabPay may adjust with reasonable notice.
cardpayerno issuance, periodic, 3DS or SMS fee on the Visa CardHesabPay Visa Card FAQ.
fxpayerabout 1% when converting AFN to USD for card useHesabPay Visa Card FAQ; terms s1.4 says card currency exchange is at Da Afghanistan Bank rates.
limitnoneVisa Card 20,000 AFN per week, 80,000 AFN per monthHesabPay Visa Card FAQ, which says these limits are set by the Central Bank.

No published tariff for transfers, E-Hawala cash-out or agent cash-in was found on hesab.com (sitemap read 2026-10-09; /fees and /pricing return 404). Those components are unknown, not zero.

  1. Documented

    Terms and Conditions (effective 2026-04-06) s4.1 Monthly Maintenance Charges; s2.2 says statements carry no fee.

    hesab.com/terms

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

  2. Documented

    HesabPay Visa Card FAQ items 05 (fees) and 06 (limits).

    hesab.com/visa/FAQs

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

Custody model

Evidenced

Provider-custodial

Evidence shared with CROPS: S1 item 1, C2 item 1

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

Licences and registrations

Evidenced
EntityCountryRegulatorLicenceRegister
Zinzir Ltd (HesabPay)AfghanistanDa Afghanistan BankElectronic money institution licence · EMI101005
Electronic money institution; licence date 5 June 2023
register

The terms and privacy policy name HesabPay, Inc. (Delaware) as the contracting party. Neither document states how it relates to the licensee Zinzir Ltd. HesabPay's September 2026 security post says the official app is published under the Zinzir Ltd. brand. No US money-transmitter licence was looked for.

  1. Documented

    Da Afghanistan Bank list of licensed electronic money institutions: HesabPay, Name of EMI: Zinzir Ltd, license No: EMI101005, License Date: 5 June 2023, website https://hesab.com/.

    www.dab.gov.af/non-banking-financial-institutions

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

Cash-out options

Evidenced
WhereMethodPartnerFeeLimits
Afghanistancash agentHesabPay agents (1,200+, E-Hawala)
Afghanistanbank transferLinked bank accounts
everywhere offeredatmHesabPay Visa Card (partner-issued), any Visa-enabled ATM20,000 AFN per week, 80,000 AFN per month on the card

No cash-out fees are published. ALL for ATM follows the terms' "globally"; the card itself is offered only to HesabPay account holders.

  1. Documented

    Terms s2.4 E-Hawala (cash-out transfers), also usable by recipients without a HesabPay account.

    hesab.com/terms

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

  2. Documented

    Terms s1.2 services.

    hesab.com/terms

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

  3. Documented

    Terms s1.4 HesabPay Visa Card. HesabPay's July 2026 announcement describes the card as virtual, so ATM use may depend on a physical card or a wallet-enabled ATM; this was not checked.

    hesab.com/terms

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

First deployment

Unknown

No primary source dating the service launch was found. HesabPay's own July 2026 press release says Hesab was founded in 2018 (company, not service). The Da Afghanistan Bank EMI licence is dated 5 June 2023 (see changes).

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

Operating entity

Evidenced

HesabPay, Inc., US-DE

The Delaware company register was not read (its entity search sits behind a challenge page, which was not bypassed), so no registration number is recorded. The licensed entity in Afghanistan is Zinzir Ltd (see licences).

  1. Documented

    Privacy Policy s8; terms s9 put the agreement under Delaware law; contact address 2093 Philadelphia Pike, Claymont, DE.

    hesab.com/privacy

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

Security incidents

Unknown

Absence of a found incident is not evidence that none occurred.

No primary-source incident notice was found on hesab.com (sitemap and blog read 2026-10-09). HesabPay's 2026-09-01 security post warns about phishing and tampered APKs but reports no incident. No status page found.

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

Product changes affecting users

Evidenced
  • 2023-06-05: Da Afghanistan Bank EMI licence EMI101005 granted to Zinzir Ltd (HesabPay). source
  • 2026-07-24: HesabPay announced the launch of Visa virtual cards in Afghanistan (own press release). source
  1. Documented

    DAB licensed EMI list entry for HesabPay.

    www.dab.gov.af/non-banking-financial-institutions

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

  2. Documented

    HesabPay press release dated Kabul, July 24, 2026.

    hesab.com/resources/blog/hesabpay-launches-visa-cards-what-users-should-know

    checked 2026-10-09 · source unchanged at weekly re-read 2026-10-19

UnreviewedAssessed by AI research agent (operational), 2026-10-09Checked 2026-10-09

Volume transacted (verified only)

Not verifiable

Closed custodial ledger. HesabPay describes using Algorand, but no HesabPay document links a settlement address or asset, so nothing can be read and attributed from a chain. Reported figures are not recorded.

UnreviewedAssessed by AI research agent (operational), 2026-10-09

Group B: institutional due diligence

ControlStateWhat was found
Assurance and certifications
B1.1 ISO 27001, developer organisation
Is the organisation that develops the product ISO 27001 certified, and does the certificate name that entity?
Unknown
No ISO 27001 statement or certificate found on hesab.com, the terms or the privacy policy.
B1.2 ISO 27001, hosting and support organisation
Is the organisation that hosts and supports the service ISO 27001 certified in its own name, with a scope covering the service?
Unknown
B1.3 SOC 2 Type II or ISAE 3000/3402 reports
Does the provider undergo periodic SOC 2 Type II or ISAE 3402 Type II assessments and make reports available?
Unknown
B1.4 Independent source-code security review before go-live
Was the application reviewed by an independent party before launch, and is the report linked?
Unknown
B1.5 Penetration testing
Is the service penetration-tested before go-live and at least every three years, with results available?
AttestedThe privacy policy states regular security audits and penetration testing; no report, date or tester is named.
source 1
B1.6 Vulnerability scanning cadence
Are the platform and the application scanned for vulnerabilities at least every six months?
Unknown
Vulnerability and patch management
B2.1 Security contact and disclosure policy
Is there a published way to report a vulnerability (SECURITY.md, security.txt, or a disclosure page)?
Unknown
implied from the component list
B2.2 Patch service levels
Does the provider commit to patch timelines for known vulnerabilities (the partner expects 30 days critical, 40 high, 90 medium)?
Unknown
B2.3 Dependency and vulnerability scanning in CI
Do the public repositories run dependency or code scanning automatically?
Unknown
implied from the component list
Incident reporting and continuity
B3.1 Incident reporting commitment
Does the provider commit to notify customers of security or data incidents within a stated time (the partner expects 24 hours)?
Unknown
The privacy policy commits to notify users of material policy changes, not of incidents.
B3.2 Backups and restore testing
Are customer records backed up daily and restores tested on a schedule?
Unknown
B3.3 Recovery plan
Is there an approved and tested recovery plan for the service?
Unknown
B3.4 Status page and post-mortems
Does the provider publish service status and post-mortems for incidents?
Unknown
No status page linked from hesab.com.
Identity and access (operator side)
B4.1 MFA for end users
Can or must end users protect accounts with multi-factor authentication?
EvidencedThe policy states multi-factor authentication for account access and high-value transactions; the September 2026 security post refers to PIN and OTP.
source 1
B4.2 MFA and separate accounts for privileged access
Is privileged access protected by MFA and kept on separate accounts?
Unknown
B4.3 Periodic access reviews
Are user access rights reviewed at least annually and privileged accounts at least six-monthly?
Unknown
B4.4 Segregation of duties and joiner-mover-leaver controls
Is there a documented segregation-of-duties model and a joiner-mover-leaver process?
Unknown
B4.5 Session timeout
Are idle interactive sessions terminated after a defined period (the partner expects 60 minutes)?
Unknown
API and integration
B5.1 API authentication, browser to server
Which standard (OAuth 2.0, OpenID Connect, SAML, JWT) protects browser-to-server API calls?
Unknown
The API reference at developers.hesab.com is a client-rendered app whose docs routes need a login; its public bundle shows no auth scheme.
B5.2 API authentication, server to server
Are server-to-server calls authenticated with keys or PKI certificates, and are keys scoped and rotatable?
Unknown
B5.3 Token expiry
Do API tokens expire, and within what period (the partner caps it at 120 minutes for public data, 30 otherwise)?
Unknown
B5.4 Export controls
If an API exports data, does it limit volumes and log exports?
Unknown
Data protection and privacy governance
B6.1 Data classification and encryption
Does the provider state a data classification and enforce encryption at rest and TLS 1.2 or better in transit?
EvidencedPolicy states encryption at rest and in transit. Observed: hesab.com refuses TLS 1.1 and accepts TLS 1.2. No data classification found.
source 1 · source 2
B6.2 Production data kept out of test environments
Does the provider state that production or real personal data is not used in development and testing?
Unknown
B6.3 Data retention and deletion on termination
What is retained, for how long, and is customer data removed on termination?
EvidencedPersonal data kept while the account is active or as needed; transaction records at least 5 years; account deletion on request except where law requires retention.
source 1
B6.4 Data protection impact assessment and roles
For systems holding personal data, has a DPIA been completed and are controller and processor defined?
Unknown
The privacy policy speaks as HesabPay, Inc. but does not use controller or processor terms, and no DPIA is mentioned.
B6.5 Data processing or sharing agreement available
Can a customer obtain a data processing agreement or equivalent?
Unknown
Logging and monitoring
B7.1 Audit logging
Are account changes, logins and activity on important records logged and retained?
Unknown
The policy describes "blockchain-secured audit trails" for transaction records; no account-change or login logging statement was found.
B7.2 Central monitoring and endpoint detection
Are logs sent to a managed SIEM and is endpoint detection running on all platforms?
Unknown
Hosting and network
B8.1 Hardened hosting
Are hosts hardened to a recognised benchmark, with only essential ports open, IDS/IPS, a WAF for internet-facing applications and tenant isolation?
Unknown
B8.2 Deployment configuration and infrastructure as code
Does the repository ship reproducible deployment configuration (containers, IaC, Helm) that a self-hoster can harden?
Unknown
implied from the component list
Engineering practice in public repositories
B9.1 Default branch protected
Does the default branch require reviews and passing checks, with no direct pushes?
Unknown
implied from the component list
B9.2 CI runs on pull requests
Does every pull request trigger automated checks?
Unknown
implied from the component list
B9.3 Tests run in CI
Do the CI workflows run the test suite?
Unknown
implied from the component list
B9.4 Coverage reported
Is test coverage measured and reported (the partner expects 85%)?
Unknown
implied from the component list
B9.5 Versioned releases
Are releases tagged with immutable semantic versions?
Unknown
implied from the component list
B9.6 Signed tags or commits
Are release tags or recent commits cryptographically signed?
Unknown
implied from the component list
B9.7 Changelog
Is a changelog maintained with the code?
Unknown
implied from the component list
B9.8 Contribution and branching model documented
Does the README or contribution guide state how changes are proposed, reviewed and released?
Unknown
implied from the component list
Architecture documentation
B10.1 Architecture documentation
Is there a public architecture document covering logical, infrastructure and integration architecture and the components used?
Unknown
No public architecture document found; developer docs need a login.
Commercial and financial
B11.1 Contracting entity
Which legal entity would an institution contract with, and in which jurisdiction?
EvidencedHesabPay, Inc. (Delaware, US), per the terms; Delaware law governs. Licensee in Afghanistan is Zinzir Ltd.
source 1
B11.2 Funding of ongoing operation
How is ongoing operation and maintenance funded (revenue, foundation, grants, fee switch), per a primary source?
EvidencedCustomer fees (monthly maintenance charges, card FX); no other funding source was read.
source 1
B11.3 Termination terms
What happens to customer funds and data on termination by either side?
EvidencedTerms list termination grounds (fraud, breach, unregistered phone, court or government order) with no notice period and no statement of what happens to balances on termination; s2.3 says funds can be withdrawn at any time.
source 1
AI components
B12.1 AI in the payment path
Does an AI system take part in payment processing or compliance decisions (for example automated transaction screening)?
EvidencedYes: the Ask HesabPay AI assistant initiates transactions from natural-language commands (standard authentication still applies), and inputs go to third-party language-model providers. The policy also states automated fraud detection and real-time transaction monitoring.
source 1
B12.2 AI controls documented
If AI is used, are monitoring, validation, override, decommissioning and bias evaluation documented?
Unknown
The policy says AI inputs are not used to train third-party models; no monitoring, override or bias-evaluation documentation found.

Scope of assessment

Components in the payment path

ComponentRolePublicLicenceOperatorRequired
HesabPay custodial wallet ledger and transaction backendledgerNoproprietaryHesabPayYes
Partner banks holding customer funds 1:1 (not named in sources read)otherNoproprietaryLicensed partner banksNo
HesabPay mobile appwalletNoproprietaryHesabPayNo
USSD *580# servicefrontendNoproprietaryHesabPayNo
web.hesab.com web wallet and enterprise web platformfrontendNoproprietaryHesabPayNo
Merchant REST API (api.hesab.com) and developer portal (developers.hesab.com)apiNoproprietaryHesabPayNo
HesabPOS terminals and mPOS devicesotherNoproprietaryHesabPayNo
Identity verification (KYC) via verification services and government databaseskycNoproprietaryHesabPay and unnamed identity verification servicesNo
HesabPay Visa Card (issued with partner banks)card-issuerNoproprietaryLicensed partner banks (not named in sources read)No
Visa card networkcard-networkNoproprietaryVisaNo
Cash-out agent network (1,200+ agents per terms s2.4)otherNoproprietaryHesabPay agentsNo

Repositories

None found. Absence of public code is itself a finding.

Contracts

None listed.

Assessor notes

Eligibility: no public repository owned by HesabPay and no verified contract found, so type is incumbent. Searched 2026-10-07: gh search repos hesabpay / hesab; gh search code hesabpay; GitHub users/orgs hesabpay, HesabPay, hesab-pay, hesabpay-official, hesabpayglobal (all 404) and user search "hesabpay" (two unrelated accounts: HesabPayZinzir with 0 repos, habib-studio). Every hesabpay repo found is a third-party merchant integration (WooCommerce, Laravel, Django, Flutter) calling HesabPay's hosted API, not code needed to run the product. Blockscout search "hesab" on Ethereum returned nothing; hesab.com, its privacy policy, terms and the developer-portal bundle contain no EVM address or contract reference. hesabpay.com returns a Cloudflare 403 to non-browser clients; the operating site is hesab.com, which the privacy policy names as the website. HesabPay is described on hesab.com and in an Algorand Foundation case study (claimed tier) as running on Algorand. Algorand ASAs named "HesabPay" exist (e.g. 1258542524, 3561304383) whose self-asserted url field points at hesab.com, but no HesabPay document links to them, ASAs carry no verifiable source, and the schema does not represent Algorand; they are logged in docs/research/hesabpay.md and not used. Scores rest on the terms and privacy policy (documented tier, cap 1) and one reproducible page fetch.