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.

Opera MiniPay

incumbentOff-chain No public chain settlementminipay.to

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 · 9 no evidence
Security audits
4 published
Offered
All but 1 countries
Last edited
2026-10-13 · History
  1. Censorship Resistance0 FailsWeakest: Admin pause or freeze powers; Reliance on hosted services
  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. Security No evidenceWeakest: Who can upgrade the code; Token approval scope; Secrets and webhook handling; Audits and bug bounty

Where it is offered

Offered everywhere except the countries listed. Checked 2026-10-09. Not scored.

The terms say the MiniPay Service is available only to users in "qualifying countries" and is void where prohibited, but neither the terms, the FAQ nor the site publishes the list of qualifying countries. The only country the terms name is the People's Republic of China, where Blueboard offers no crypto-related services, so CN is the only entry. This is a floor, not a claim that MiniPay is offered everywhere else: availability elsewhere depends on the unpublished qualifying-country list, and users also warrant they are not on any trade embargo or sanctions list (no list named). The site's "send to 70+ countries" and the FAQ's "53 countries" and "over 60 countries" for local top-up describe transfer and ramp reach, not where the wallet is offered. The MiniPay Card is offered only "in selected supported markets", also unlisted. The underlying Celo contracts have no country restriction; this block describes the MiniPay app.

Excluded countries (1): China

Evidence (2)2 documented
  1. Documented

    MiniPay (Blueboard Limited) terms of service, general terms; same section says the Services are made available to users in qualifying countries and are void where prohibited.

    minipay.to/terms-of-service

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

  2. Documented

    MiniPay Service section of the terms; the qualifying countries are not listed anywhere on minipay.to.

    minipay.to/terms-of-service

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

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

What would raise this pillar

  • Admin pause or freeze powers reaching Weak: Role held by a multisig that misses one of those conditions (no timelock, undisclosed signers, bypass modules), or the constraints are documented only.
  • Reliance on hosted services reaching Weak: Intermediaries required, only documented, no public code.

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

Blueboard can cut an individual user off from the MiniPay app at any time with no notice, which blocks the MiniPay payment path for that user. MiniPay has no settlement contracts of its own: transfers are plain stablecoin transfers on Celo, and issuer freeze powers over USDC and USDT belong under C5. Judgment call: scored 0 on the termination power over the app path. The user's keys stay with the user (see C2 and S4), so the funds themselves are not frozen by this power.

Evidence (1)1 documented
  1. Documented

    Blueboard Terms of Service, general section: Blueboard may terminate an individual user's access to the Services at any time, with or without notice.

    minipay.to/terms-of-service

    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

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

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

A MiniPay payment is an ERC-20 transfer on Celo signed with a key the user holds, so a user holding the recovery phrase can settle by calling the token contract directly from any Celo wallet. This is shown by terms and docs only. No trace of exporting a MiniPay key and settling elsewhere was run, so the documented cap of 1 applies.

Evidence (2)2 documented
  1. Documented

    MiniPay service terms: the app stores a key pair with an encrypted private key; assets live on Celo; 'Neither your key pair nor the Secret Recovery Phrase is available to us.'

    minipay.to/terms-of-service

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

  2. Documented

    Celo docs list MiniPay's three stablecoins with their Celo mainnet addresses and show a payment as a plain ERC-20 transfer() call.

    docs.celo.org/build/mini-apps/overview.md

    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

Using MiniPay requires an account with Blueboard's closed backend, reached only through Blueboard's closed app. No intermediary code is public and no alternative operator exists. The RPC endpoint the app uses was not identified. Judgment call: anchor 1 (documented, no public code) and anchor 0 (closed, single-vendor) both fit; took 0.

Evidence (2)2 documented
  1. Documented

    Privacy statement section 2: a phone number is collected to set up a MiniPay account; Technical Data (IP, UID, device data) and Transactional Data are collected by Blueboard when the app is used.

    minipay.to/privacy-statement

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

  2. Documented

    Terms EULA section: the Software Services are licensed as executable code only; copying, decompiling and deriving source are prohibited.

    minipay.to/terms-of-service

    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

Geographic and sanctions gating at the app edge is disclosed in the terms. The terms do not name the list source or the country list. Whether the closed app or backend filters addresses or transactions cannot be checked from code. The settlement layer (Celo plus the stablecoin contracts) is outside MiniPay and was not examined here.

Evidence (1)1 documented
  1. Documented

    Terms: MiniPay is limited to qualifying countries (the general section excludes the People's Republic of China); users warrant they are not on any trade embargo or economic sanction list.

    minipay.to/terms-of-service

    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

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

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

The chain and supported tokens are listed in docs. No user-facing document read states the USDC and USDT issuers' freeze or blacklist powers or the Celo sequencer assumptions. No MiniPay code is public, so the token list cannot be shown in code.

Evidence (1)1 documented
  1. Documented

    Celo's MiniPay page enumerates the chain (Celo mainnet 42220) and the three tokens (USDm 0x765DE816845861e75A25fCA122bb6898B8B1282a, USDC 0xcebA9300f2b948710d2653dD7B07f33A8B32118C, USDT 0x48065fbBE25f71C9282ddf5e1cD6D6A887483D5e).

    docs.celo.org/build/mini-apps/overview.md

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

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: VerifiedChecked 2026-10-19 today

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

No component of MiniPay itself (app, backend, issuer service) is public. The public MiniPay code is Celo's partner snippets and Mini App templates, which do not run the wallet.

Evidence (2)1 verified · 1 documented
  1. Verified

    The only repo named for MiniPay that carries MiniPay-specific values is celo-org/minipay ('MiniPay snippet code for external partners'): balance, gas and SocialConnect lookup snippets, no LICENSE file. github.com/opera (13 repos) and github.com/operasoftware (137 repos) contain no MiniPay code.

    celo-org/minipay · README.md

    commit a25a3a23be · checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

  2. Documented

    Terms EULA: the app's source code is described as a trade secret and Blueboard's exclusive property.

    minipay.to/terms-of-service

    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

The Mini App interface is documented on a hosted docs site, not versioned in a public repo. No payee data export format is documented. Settlement uses standard ERC-20 ABIs that MiniPay does not define.

Evidence (1)1 documented
  1. Documented

    MiniPay developer docs document the injected EIP-1193 provider, custom methods (getExchangeRate, scanQrCode, requestContact) and token transfer examples for Mini Apps.

    docs.minipay.xyz/technical-references.md

    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 app and backend needed to run MiniPay are proprietary and closed. A third party cannot fork them.

Evidence (1)1 documented
  1. Documented

    Terms EULA: a personal, non-transferable licence to the executable code only; copying, modification and derivative works are prohibited.

    minipay.to/terms-of-service

    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 · 1 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

An attribution/analytics SDK (AppsFlyer) and Firebase messaging are in the app, disclosed in the privacy statement. Whether they are on by default, and what they send, could not be checked: the app is closed and no trace was run.

Evidence (1)1 documented
  1. Documented

    Privacy statement section 5 names AppsFlyer and Firebase Cloud Messaging as third-party code in MiniPay and lists 'analytic system technology providers' among processors.

    minipay.to/privacy-statement

    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

MiniPay collects identity, device and behavioural data and links transactions to a user ID, well beyond addresses and amounts. All of this is disclosed in the privacy statement, and part of it is used for marketing and product analytics rather than any legal requirement. Judgment call: anchor 1 (disclosed in a policy) and anchor 0 (collection beyond the stated legal requirement) both fit; took 0.

Evidence (2)2 documented
  1. Documented

    Privacy statement: collects phone number, receiver phone number, IP, UID, device data and in-app actions, wallet address and holdings, and transaction type and amount linked to the UID; processed for contract, legitimate interests, legal compliance and marketing.

    minipay.to/privacy-statement

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

  2. Documented

    Privacy statement section 3 lists marketing and preference analysis among the purposes of processing.

    minipay.to/privacy-statement

    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

0 Fails

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

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

Each payment is a plain stablecoin transfer, which links payer and payee publicly. In addition, MiniPay's issuer publishes onchain an attestation that ties each registered wallet address to an ODIS-obfuscated phone identifier. That marks the address as a MiniPay account, and anyone with ODIS quota can resolve a phone number to it. The user-facing privacy statement says no personal data goes to blockchain networks. Judgment call: the attestation is described in developer docs but not to users, so the linkage is treated as undisclosed; 0 rather than 1.

Evidence (3)2 verified · 1 documented
  1. Verified

    FederatedAttestations emitted 1975 AttestationRegistered events with issuer = MiniPay issuer 0x7888612486844Bb9BE598668081c59A9f7367FBc in blocks 79454281-79459279. Example: lookupIdentifiers(0xad14248c1A6401162Abbe73047c941397b22F5c2, [MiniPay issuer]) at block 79459279 returns the phone-derived identifier 0xda87e60402949f20227d37ae0693c65441a0cafe18435dd982c5b2cf1eafb9a5.

    0x0aD5…aff2 on celoscan.io

    0x0aD5…aff2 explorer · Sourcify · block 79459279 · checked 2026-10-07

  2. Verified

    Celo's MiniPay partner snippets name 0x7888612486844Bb9BE598668081c59A9f7367FBc as 'the MiniPay issuer address on Mainnet' for phone-number lookups.

    celo-org/minipay · README.md

    commit a25a3a23be · checked 2026-10-07 · source unchanged at weekly re-read 2026-10-19

  3. Documented

    The privacy statement says no personal data is shared with blockchain networks.

    minipay.to/privacy-statement

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

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 in and around the payment flow are disclosed by category in the privacy statement. The ramp providers and the RPC provider are not named, and none of this can be checked or swapped in code because the app is closed.

Evidence (1)1 documented
  1. Documented

    Privacy statement section 5 lists Opera Group companies, text-message, support and analytics providers, on/off-ramp and swap providers, AppsFlyer, Firebase Cloud Messaging, WhatsApp and Telegram (Indonesia).

    minipay.to/privacy-statement

    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?

No evidencePillar 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

By the terms, MiniPay is self-custodial and payments go directly from payer to payee as token transfers. That matches anchor 3, but it rests on documents only: key generation and storage in the closed app cannot be checked. The documented cap of 1 applies.

Evidence (1)1 documented
  1. Documented

    MiniPay service terms: the app generates the key pair on the device, stores an encrypted private key, and backs up the recovery phrase to the user's Google account; Blueboard says it has no access to either.

    minipay.to/terms-of-service

    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

1 Weak

Best evidence: DocumentedChecked 2026-10-19 today

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

Derived. S1 = 1 (self-custody per terms, documented cap), C2 = 1 (direct ERC-20 transfer possible with the user's key, documented only), C3 = 0 (closed single-vendor app and backend), O3 unknown (nothing public to self-host). If Blueboard disappears, a user with the recovery phrase can move funds through another Celo wallet. This is documented, not verified, and the MiniPay app path itself stops.

Evidence (1)1 documented
  1. Documented

    Terms: user-held keys and recovery phrase; assets held on Celo, not by Blueboard (see S1, C2).

    minipay.to/terms-of-service

    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 4

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.

DateAuditorTypeScopeCovers deployed codeFindings
2026-02-17ChainSecurityAuditShared component: Mento Core v3, including StableTokenV3 and StableTokenSpoke (the USDm token contracts), FPMM swaps, liquidity strategies, oracle adapter and ReserveV2 at 0e07807c22
Five review rounds from 22 October 2025 (683af1f) to the final version 0e07807. USDm is one of the tokens MiniPay users hold and send; whether the USDm proxy on Celo points to the audited StableTokenV3 was not checked.
Unknown0 critical, 0 high, 7 medium, 9 low; 9 code corrected, 1 specification changed, 1 partly corrected, 5 risk accepted
2024-12-19Trail of BitsAuditCelo L2 blockchain (OP Stack fork): token duality, fee currencies, alt-DA, L1-to-L2 data migration; celo-monorepo contracts, celo-org/op-geth and celo-org/optimism at c6d7b55
Targets: celo-monorepo 89591e1 and PR #11261, op-geth c6d7b55, optimism 50977c3; review October-November 2024. Celo mainnet has since moved to later rebases of op-geth and optimism (celo-rebase-17/18), so the audit covers an earlier version of the chain MiniPay settles on.
Partly0 high, 2 medium, 4 low, 4 informational
2022-09-20Verilog SolutionsAuditShared component: Celo OdisPayments contract and proxy (ODIS quota payments made by SocialConnect issuers such as MiniPay's), celo-monorepo PR #9740 at 4bf959b
Listed as a Core Contracts Release 8 audit in the Celo forum release post. Used only in the optional phone-number lookup flow.
Unknown1 medium (cUSD paid in cannot be withdrawn; acknowledged), 1 informational (resolved)
2022-07HackenAuditShared component: Celo Core Contracts Release 8 (per the Celo forum post, the release that added FederatedAttestations and updated Escrow); exact contract list not read
Linked as the Core Contracts Release 8 audit report in the Celo forum post "Core Contracts Release 8" (forum.celo.org/t/core-contracts-release-8/4050) and in the cLabs Identity Team milestone post. The URL returns HTTP 403 to scripted requests, so the report was not read; the date is taken from the file name. FederatedAttestations holds the MiniPay issuer's phone attestations.
Unknown

Compiled from: minipay.to and Opera's press and security blog pages (no MiniPay audit linked), github.com/celo-org/minipay, the security-reviews folders of celo-org/celo-monorepo and celo-org/optimism (the latter holds upstream OP Stack reviews, not listed here), the Celo forum (L2 audit and Core Contracts Release 8 posts), mento.org/audits and ChainSecurity's Mento reports, and web searches for MiniPay, ODIS and SocialConnect audits. No audit of the MiniPay app, backend or issuer service was found. Not listed: Immunefi's Nov-Dec 2024 Celo competition (L1-to-L2 migration tooling and stCelo); Mento's Hats, Sherlock and Macro entries (no report linked); the ChainSecurity Mento Liquity v2 audit. 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, 0 attested, 0 absent, 3 not applicable, 35 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
providernoneno MiniPay fee on wallet transfersMiniPay FAQ; set by Blueboard and changeable.
networkpayerCelo network fee, stated as typically under $0.01Celo gas, payable in stablecoins; set by the network, not MiniPay.
providerpayee$1 + 1% on deposits to a USD virtual account; EUR 1 + 1% on EURMiniPay FAQ (virtual accounts provided by NOAH).
cardnoneno issuance or monthly MiniPay Card feeMiniPay FAQ; Visa exchange rates and fees may apply on non-USD purchases.
cashoutpayerset by third-party ramp providers; FAQ says fee-free local-currency withdrawals are available through someMiniPay FAQ; partner fees are not published by MiniPay.

Judgment call. The provider file treats the FAQ as claimed (support content) for CROPS scores, but here it is cited as documented because it is the operator's only published pricing statement. Ramp-partner fees are unknown.

  1. Documented

    MiniPay FAQ, "Does MiniPay charge fees?".

    minipay.to/faq

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

  2. Documented

    MiniPay FAQ, "Are there any fees for receiving payments?" (virtual accounts).

    minipay.to/faq

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

  3. Documented

    MiniPay FAQ, card fees.

    minipay.to/faq

    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

Self-custody

Self-custody per the terms (key pair generated on device, recovery phrase backed up to the user's Google account, "not available to us"). The app is closed, so this rests on documents only (CROPS S1 holds at the documented cap). The MiniPay backend still holds account and transaction data, so operator controls apply.

Evidence shared with CROPS: S1 item 1

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

Licences and registrations

Unknown

No licence held by Blueboard Limited was found in the terms, privacy statement, FAQ or minipay.to. The terms say Blueboard offers no exchange services and that buying and selling crypto assets is provided by third parties under their own terms, so any licences sit with the unnamed ramp and virtual-account partners (NOAH named for virtual accounts). No regulator register was searched for Blueboard.

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

Cash-out options

Evidenced
WhereMethodPartnerFeeLimits
everywhere offeredexchangeIntegrated third-party ramp partners (not named per country)Partner-set; not published by MiniPay

The payout method (bank, mobile money or other) depends on the ramp partner in each country, and MiniPay publishes no per-country partner list, so the method is recorded as exchange through a ramp. Because the wallet is self-custodial, a user can also move stablecoins to any exchange on Celo. The MiniPay Card is digital-only, and no ATM withdrawal is documented.

  1. Documented

    MiniPay FAQ, "How can I withdraw my funds from MiniPay?"; top-ups and withdrawals are provided by third parties.

    minipay.to/faq

    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

Evidenced

2023-09-13: MiniPay unveiled inside Opera Mini; rollout began in Nigeria.

  1. Documented

    Opera press release dated Oslo, September 13, 2023.

    press.opera.com/2023/09/13/opera-launches-minipay

    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

Operating entity

Evidenced

Blueboard Limited, IE

Jurisdiction IE comes from Opera Ltd's Form 20-F for 2020 (SEC accession 0001437749-21-014514, exhibit 8.1 list of subsidiaries, "Blueboard Limited Ireland"), read 2026-10-09. sec.gov returns 403 to the validator's user agent, so it is not cited as an evidence URL. The Irish Companies Registration Office entry was not read, so no registration number is recorded.

  1. Documented

    MiniPay terms of service (last update April 27, 2026); governed by Norwegian law with the Oslo City Court as venue.

    minipay.to/terms-of-service

    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 incident notice was found on minipay.to, the MiniPay blog or Opera's Africa blog. No status page was found.

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

Product changes affecting users

Evidenced
  • 2023-10-18: After a month-long initial rollout, MiniPay opened to all Opera Mini users in Nigeria. source
  • 2023-11-06: MiniPay launched to all Opera Mini users in Kenya. source

Later changes (standalone apps, virtual accounts, MiniPay Card) were not dated from a primary source here.

  1. Documented

    Opera Africa blog, October 18th, 2023.

    blogs.opera.com/africa/2023/10/minipay-now-open-to-all-users-in-nigeria

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

  2. Documented

    Opera Africa blog, November 6th, 2023.

    blogs.opera.com/africa/2023/11/minipay-now-available-to-all-users-in-kenya

    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

MiniPay transfers are ordinary stablecoin transfers on Celo, but the provider file lists no settlement contracts. The only MiniPay-specific onchain marker is the SocialConnect issuer's attestations, which identify registered addresses, not MiniPay-originated transfers. A volume figure would need an attribution method that has not been reviewed. 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 for Blueboard Limited or Opera found; not in the Coalfire Certification directory (checked for Wise).
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?
Unknown
Opera runs public and private bug bounties (security.opera.com, bugcrowd.com/opera); whether MiniPay is in scope was not established, and no penetration-test report was found.
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
B3.2 Backups and restore testing
Are customer records backed up daily and restores tested on a schedule?
N/A: falls to the institution
Self-custody per the terms. Funds sit on Celo under user-held keys, and the recovery phrase is backed up to the user's own Google account, not by Blueboard. Backups of Blueboard's account and transaction metadata are not covered by this control and were not found.
B3.3 Recovery plan
Is there an approved and tested recovery plan for the service?
N/A: falls to the institution
Self-custody per the terms. If the app stops, recovery is the user's recovery phrase in another Celo wallet (CROPS S4, documented only).
B3.4 Status page and post-mortems
Does the provider publish service status and post-mortems for incidents?
Unknown
No status page found.
Identity and access (operator side)
B4.1 MFA for end users
Can or must end users protect accounts with multi-factor authentication?
EvidencedAccess and recovery go through the user's Google Account login. Any MFA is whatever the user sets on that Google account; MiniPay states no MFA of its own.
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)?
N/A: no such service
implied from the component list
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 documented Mini App interface is an injected EIP-1193 provider in the app (CROPS O4); the authentication of the app-to-backend API is not documented.
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?
EvidencedObserved: minipay.to refuses TLS 1.1 and accepts TLS 1.2. The terms say the private key is stored encrypted on the device. No statement on server-side encryption at rest or data classification was found.
source 1
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?
EvidencedContact, technical, personal and wallet data kept for two years after use ends; transactional data while active and for two years after. Deletion on request through an online form. See CROPS P2 for what is collected.
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?
EvidencedBlueboard Limited is the data controller under the GDPR; a Data Protection Officer is reachable by form; the Irish DPC and Norway's Datatilsynet are named as supervisory authorities. DPIA availability not found.
source 1
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
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?
EvidencedIntegration view only (docs.minipay.xyz documents the injected provider, custom methods and token transfers for Mini Apps); the logical and infrastructure architecture of the app and backend is not published.
source 1
Commercial and financial
B11.1 Contracting entity
Which legal entity would an institution contract with, and in which jurisdiction?
EvidencedBlueboard Limited (Opera Group; Ireland per Opera's 20-F subsidiary list). Terms governed by Norwegian law, with the Oslo City Court as venue.
source 1
B11.2 Funding of ongoing operation
How is ongoing operation and maintenance funded (revenue, foundation, grants, fee switch), per a primary source?
Unknown
MiniPay charges no wallet fees. It takes deposit fees on virtual accounts and pays card cashback; it is part of the Opera Group. No primary source on how its ongoing operation is funded was read.
B11.3 Termination terms
What happens to customer funds and data on termination by either side?
EvidencedBlueboard may terminate access at any time, with or without notice; termination ends the software licence. Funds stay on Celo under the user's keys (self-custody per the terms), so exit is through the recovery phrase.
source 1
CROPS S4
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)?
Unknown
The terms and privacy statement (searched for AI, automated decision-making and machine learning) do not mention AI in payment processing or compliance. The app is closed, so absence cannot be shown.
B12.2 AI controls documented
If AI is used, are monitoring, validation, override, decommissioning and bias evaluation documented?
Unknown

Scope of assessment

Components in the payment path

ComponentRolePublicLicenceOperatorRequired
MiniPay app (Android, iOS, Opera Mini embed)walletNoproprietaryBlueboard Limited (Opera Group)Yes
MiniPay backend (account, phone verification, transaction metadata)backendNoproprietaryBlueboard Limited (Opera Group)Yes
MiniPay SocialConnect issuer and attestation signersignerNoproprietaryBlueboard Limited (Opera Group)No
ODIS (phone-number obfuscation service)oracleYesApache-2.0Celo / cLabsNo
FederatedAttestations core contractcontractsYesApache-2.0Celo governanceNo
Celo L2 mainnet (chain 42220)ledgerYesLGPL-3.0Celo network (sequencer operator not verified here)Yes
Celo RPC endpoint used by the app (not identified)apiNoproprietaryunknownYes
USDm stablecoin (Mento)otherYessource-availableMentoNo
USDC stablecoin issuerotherNoproprietaryCircleNo
USDT stablecoin issuerotherNoproprietaryTetherNo
On-ramp, off-ramp and swap providersotherNoproprietaryThird parties (not enumerated in the policy)No
Third-party KYC (e.g. SumSub) for ramp and card serviceskycNoproprietaryThird partiesNo
AppsFlyer and Firebase Cloud Messaging SDKsotherNoproprietaryAppsFlyer; GoogleNo
Google Drive key backupotherNoproprietaryGoogleNo

Repositories

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

Contracts

None listed.

Assessor notes

Incumbent by the eligibility rule: no verified contract and no public repository needed to run MiniPay was found. MiniPay is a closed, self-custodial stablecoin wallet app (Android, iOS, inside Opera Mini) offered by Blueboard Limited (Opera Group) on Celo mainnet (chain 42220). It settles in third-party stablecoins (USDm, USDC, USDT) and maps phone numbers through Celo's generic SocialConnect stack (ODIS plus the FederatedAttestations core contract 0x0aD5b1d0C25ecF6266Dd951403723B2687d6aff2). The one MiniPay-specific onchain element is its SocialConnect issuer, 0x7888612486844Bb9BE598668081c59A9f7367FBc, which has no code (an EOA), so it is not a verified contract. MiniPay-related public repos all belong to celo-org (snippets, Mini App templates, workshops); none runs the wallet. The Opera and operasoftware GitHub orgs have no MiniPay repo, and github.com/minipay is an unrelated 2019 org. www.opera.com/products/minipay redirects to minipay.to, which links the terms, privacy statement and docs.minipay.xyz. The FAQ on minipay.to is support content, so it is claimed tier and holds no score up. Search log: docs/research/minipay.md.