Q2 2026 Security & Compliance Report67 incidents, $764M in losses, 88% from operational failures.
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Audit name:

[SCA] Europeum | TPR | Jul2026

Date:

Aug 13, 2026

Table of Content

Introduction
Audit Summary
System Overview
Potential Risks
Findings
Appendix 1. Definitions
Appendix 2. Scope
Appendix 3. Additional Valuables
Disclaimer

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Introduction

We express our gratitude to the Europeum team for the collaborative engagement that enabled the execution of this Smart Contract Security Assessment.

The in-scope contracts form the Policy Registry module of the EBSI (European Blockchain Services Infrastructure) on-chain identity and access stack, an EVM-based Solidity system. The registry stores named policy definitions and assigns them as attributes to user addresses, allowing other contracts to query whether a given user holds a given policy via checkPolicy.

Document

NameSmart Contract Code Review and Security Analysis Report for Europeum
Audited ByKornel Światłowski
Approved ByIvan Bondar
Websitehttps://europeum.eu/
Changelog28/07/2026 - Preliminary Report
03/08/2026 - Final Report
13/08/2026 - Updated Final Report
PlatformPrivate Chain
LanguageSolidity
TagsRegistry, Storage, Upgradable
Methodologyhttps://docs.hacken.io/methodologies/smart-contracts
  • Document

    Name
    Smart Contract Code Review and Security Analysis Report for Europeum
    Audited By
    Kornel Światłowski
    Approved By
    Ivan Bondar
    Changelog
    28/07/2026 - Preliminary Report
    03/08/2026 - Final Report
    13/08/2026 - Updated Final Report
    Platform
    Private Chain
    Language
    Solidity
    Tags
    Registry, Storage, Upgradable

Review Scope

Repositoryhttps://gitlab.com/europeum/public/core-services
Commit89bb63b74e88c7e3b1602f4801d682e634b6a521
Final Commita64e3139c3a139da5bc3ff81c4d25fb35212c7f2
Updated Final Commitd1535bacb0ee03fc987339c58324b34c3db14687

Audit Summary

11Total Findings
11Resolved
0Accepted
0Mitigated

The system users should acknowledge all the risks summed up in the risks section of the report

Documentation quality

  • Functional requirements are present, but only at a high level

    • PolicyRegistry function NatSpec @notice describes behavior, both scopes (global vs. per-target), and roles.

    • Access-control intent (onlyOperatorOrProxyOwner, checkPolicy fallback) explained inline.

    • No whitepaper, no functional-requirements doc.

    • No use cases, user flows, or interaction descriptions.

    • Subtle checkPolicy scope logic (target = msg.sender) not documented for integrators.

  • Technical description is detailed.

    • Test suite present (policy, userattr, scoped-delegation specs) plus coverage script.

    • PolicyRegistry NatSpec has @param/@return and @dev validation rules.

    • No run instructions in README.

    • No standalone technical spec (architecture, deployment, storage layout).

Code quality

  • Modern Solidity version 0.8.26 (not outdated).

  • Correct OZ primitives, _disableInitializers(), __gap for upgrades.

  • Consistent custom errors and events on all state changes.

  • Dev environment configured (Hardhat 3, Solidity 0.8.26, optimizer, solhint, eslint).

  • Runs locally, no external keys (default test mnemonic).

Test coverage

Code coverage of the project is 94.03% (branch coverage).

  • Deployment and basic user interactions are covered with tests.

  • Negative case coverage is missing.

System Overview

The module centers on a single upgradeable contract, PolicyRegistry, deployed behind a versioned beacon proxy. It inherits AccessControlUpgradeable for role management, Initializable for proxy-based initialization, and ImplementationInitSelector from the external @ebsiint-sc/bootstrap package to expose the initializer selector consumed by the beacon deployment machinery. State is held in OpenZeppelin EnumerableMap and EnumerableSet structures: policy definitions are keyed by an incremental policyCount id and by a keccak256 hash of the policy name, while user assignments are tracked as composite-key sets over the tuple (user, targetContract, policyName).

Two conceptual entities are managed. Policy definitions are created and mutated by operators through insertPolicy, updatePolicy, activatePolicy, and deactivatePolicy, each policy carrying a name, a description, and an active status flag. User attribute assignments bind a user to one or more policy names within a scope: a scope of address(0) denotes an EBSI global policy, while a non-zero targetContract denotes a policy that applies only when that specific contract queries the registry. Assignments are created and removed through insertUserAttributes, insertScopedUserAttributes, deleteUserAttributes, and deleteScopedUserAttributes.

Access enforcement uses two scopes. Policy definition management and global attribute assignment are gated by OPERATOR_ROLE. Scoped attribute assignment is additionally permitted to the proxy owner of the target contract: the onlyOperatorOrProxyOwner modifier calls proxyOwner on the target through the IVersionedBeaconProxy interface and grants access when it returns the caller. The read path checkPolicy resolves a policy by id or name, then treats msg.sender as the target contract and returns true when the user holds the policy either for that specific target scope or for the global scope, giving global policies precedence-free fallback behavior. Read functions that enumerate policies, policy names, and users are paginated through the CustomPagination library, which wraps the external Pagination library from the bootstrap package and returns 1-based id slices with page metadata. The contract reserves a __gap storage slot array for upgrade-safe layout extension.

Files in Scope

  • PolicyRegistry.sol — Upgradeable registry that defines, mutates, and queries named policies and binds them to users as global or per-target-contract attributes. Exposes operator-gated write functions for policy lifecycle and attribute assignment, an onlyOperatorOrProxyOwner path for scoped assignment, and paginated read functions including the checkPolicy authorization query used by other contracts.

  • CustomPagination.sol — Library that paginates a range of incremental 1-based ids given a total count, page number, and page size. Delegates page-boundary math to the external Pagination.getPaginationParameters function and returns the id slice together with total, page-count, previous, and next metadata.

Privileged roles

PolicyRegistrysol

  • DEFAULT_ADMIN_ROLE: Admin role for all roles in the contract; granted to the initializer caller. Can grant and revoke OPERATOR_ROLE and DEFAULT_ADMIN_ROLE via the inherited grantRole and revokeRole (inherited from AccessControlUpgradeable).

  • OPERATOR_ROLE: Manages the policy catalog and global user attribute assignments; granted to the initializer caller.

    • Can call insertPolicy to create a new named policy definition.

    • Can call updatePolicy (by name or id) to change a policy description.

    • Can call activatePolicy and deactivatePolicy (by name or id) to toggle a policy's active status.

    • Can call insertUserAttributes and deleteUserAttributes to assign or remove global-scope policy attributes for a user.

    • Can call insertScopedUserAttributes and deleteScopedUserAttributes for any target contract (including address(0)).

  • Target contract proxy owner: Any address returned by proxyOwner on a target contract that implements IVersionedBeaconProxy, as enforced by the onlyOperatorOrProxyOwner modifier.

    • Can call insertScopedUserAttributes and deleteScopedUserAttributes for the specific target contract it owns.

Potential Risks

Scope limited to two of many repository contracts: The audit scope covers only PolicyRegistry and CustomPagination, whereas the repository contains numerous additional deployable contracts, including the beacon proxy and beacon implementation that host and upgrade this registry. Vulnerabilities in those out-of-scope contracts, particularly in the proxy and beacon that control the registry's storage and upgrade path, could compromise the registry despite its own correctness.

Broad operator authority over policy and attribute state: A single OPERATOR_ROLE controls the entire policy lifecycle and all global and scoped user attribute assignments through insertPolicy, updatePolicy, activatePolicy, deactivatePolicy, insertUserAttributes, insertScopedUserAttributes, deleteUserAttributes, and deleteScopedUserAttributes. A compromised operator key could deactivate policies relied upon by downstream contracts or assign and revoke arbitrary user attributes, directly altering authorization decisions returned by checkPolicy.

No timelock on authorization-critical operations: Policy activation, deactivation, and attribute assignment execute immediately with no delay or review window. Because checkPolicy is consumed by other contracts for access decisions, an immediate deactivatePolicy or deleteScopedUserAttributes call can revoke access in the same block without any buffer for review or reversal.

Concentration of initial roles in the deployer: initialize grants both DEFAULT_ADMIN_ROLE and OPERATOR_ROLE to msg.sender, concentrating role administration and operational control in the initializing account. The safety of the private key backing this account cannot be verified during a smart contract audit, and the code contains no on-chain requirement that these roles be held by a multi-signature wallet or governance contract.

Flexibility and Risk in Contract Upgrades: The project's contracts are upgradable, allowing the administrator to update the contract logic at any time. While this provides flexibility in addressing issues and evolving the project, it also introduces risks if upgrade processes are not properly managed or secured, potentially allowing for unauthorized changes that could compromise the project's integrity and security.

Absence of Upgrade Window Constraints: The contract suite allows for immediate upgrades without a mandatory review or waiting period, increasing the risk of rapid deployment of malicious or flawed code, potentially compromising the system's integrity and user assets.

Authorization outcome depends on the calling contract's identity: checkPolicy derives the target scope from msg.sender rather than an explicit parameter, so target-scoped policy checks are correct only when the querying contract is itself the intended target of the assignment. If a policy is assigned for one target contract but a different contract performs the checkPolicy call, the target-specific assignment is not matched and only the global-scope assignment can satisfy the check, which can cause access decisions to diverge from operator intent.

Report Modification: This report was modified on 13/08/2026 at the client’s request to update its original content by changing the commit hash from a64e3139c3a139da5bc3ff81c4d25fb35212c7f2 to d1535bacb0ee03fc987339c58324b34c3db14687. The files in scope were compared between these two commits and found to be identical. While these changes aim to align the report with the most current information provided by the client, it is important to note that modifying previously published content may affect the integrity and continuity of the original audit findings. Hacken has reviewed the modifications to confirm they reflect only the requested updates, but any future changes involving substantial updates or new code commits should be accompanied by a re-assessment to ensure no new risks compromise the security posture.

Findings

Code
Title
Status
Severity
F-2026-1871getUserAttributes Returns Duplicate Names Across Scopes Despite Documented Uniqueness
fixed

Observation
F-2026-1871Paginated Getters Return Clamped prev and next Values That Contradict the Documented Zero Sentinel
fixed

Observation
F-2026-1871Repeated Validation and Hashing Logic Duplicated Across Functions Instead of Shared Helpers or Modifiers
fixed

Observation
F-2026-1870Unconditional globalKey Hash Computation in _checkPolicy
fixed

Observation
F-2026-1870Loop Counters Use Post-Increment and Uncached Array Length
fixed

Observation
F-2026-1870Storage policyCount Read Every Iteration in getPolicyNamesByIds
fixed

Observation
F-2026-1870Initializer Grants Admin and Operator Roles to a Single Account and Removes Separation of Duties
fixed

Observation
F-2026-1869initialize Can Be Declared external
fixed

Observation
F-2026-1869Unconditional Set Insertion In _insertUserAttribute
fixed

Observation
F-2026-1869Redundant Keccak256 Computation In _insertUserAttribute
fixed

Observation
1-10 of 11 findings

Identify vulnerabilities in your smart contracts.

Appendix 1. Definitions

Severities

When auditing smart contracts, Hacken is using a risk-based approach that considers Likelihood, Impact, Exploitability and Complexity metrics to evaluate findings and score severities.

Reference on how risk scoring is done is available through the repository in our Github organization:

Severity

Description

Critical
Critical vulnerabilities are usually straightforward to exploit and can lead to the loss of user funds or contract state manipulation.

High
High vulnerabilities are usually harder to exploit, requiring specific conditions, or have a more limited scope, but can still lead to the loss of user funds or contract state manipulation.

Medium
Medium vulnerabilities are usually limited to state manipulations and, in most cases, cannot lead to asset loss. Contradictions and requirements violations. Major deviations from best practices are also in this category.

Low
Major deviations from best practices or major Gas inefficiency. These issues will not have a significant impact on code execution.
  • Severity

    Critical

    Description

    Critical vulnerabilities are usually straightforward to exploit and can lead to the loss of user funds or contract state manipulation.

    Severity

    High

    Description

    High vulnerabilities are usually harder to exploit, requiring specific conditions, or have a more limited scope, but can still lead to the loss of user funds or contract state manipulation.

    Severity

    Medium

    Description

    Medium vulnerabilities are usually limited to state manipulations and, in most cases, cannot lead to asset loss. Contradictions and requirements violations. Major deviations from best practices are also in this category.

    Severity

    Low

    Description

    Major deviations from best practices or major Gas inefficiency. These issues will not have a significant impact on code execution.

Potential Risks

The "Potential Risks" section identifies issues that are not direct security vulnerabilities but could still affect the project’s performance, reliability, or user trust. These risks arise from design choices, architectural decisions, or operational practices that, while not immediately exploitable, may lead to problems under certain conditions. Additionally, potential risks can impact the quality of the audit itself, as they may involve external factors or components beyond the scope of the audit, leading to incomplete assessments or oversight of key areas. This section aims to provide a broader perspective on factors that could affect the project's long-term security, functionality, and the comprehensiveness of the audit findings.

Appendix 2. Scope

The scope of the project includes the following smart contracts from the provided repository:

Scope Details

Repositoryhttps://gitlab.com/europeum/public/core-services
Commit89bb63b74e88c7e3b1602f4801d682e634b6a521
Final Commita64e3139c3a139da5bc3ff81c4d25fb35212c7f2
Updated Final Commitd1535bacb0ee03fc987339c58324b34c3db14687
Whitepaper-
RequirementsNatSpec
Technical RequirementsNatSpec
  • Scope Details

    Commit
    89bb63b74e88c7e3b1602f4801d682e634b6a521
    Final Commit
    a64e3139c3a139da5bc3ff81c4d25fb35212c7f2
    Updated Final Commit
    d1535bacb0ee03fc987339c58324b34c3db14687
    Whitepaper
    -
    Requirements
    NatSpec
    Technical Requirements
    NatSpec

Assets in Scope

contracts
policies-registry
contracts
libraries
CustomPagination.sol - contracts › policies-registry › contracts › libraries › CustomPagination.sol
PolicyRegistry.sol - contracts › policies-registry › contracts › PolicyRegistry.sol

Appendix 3. Additional Valuables

Additional Recommendations

The smart contracts in the scope of this audit could benefit from the introduction of automatic emergency actions for critical activities, such as unauthorized operations like ownership changes or proxy upgrades, as well as unexpected fund manipulations, including large withdrawals or minting events. Adding such mechanisms would enable the protocol to react automatically to unusual activity, ensuring that the contract remains secure and functions as intended.

To improve functionality, these emergency actions could be designed to trigger under specific conditions, such as:

  • Detecting changes to ownership or critical permissions.

  • Monitoring large or unexpected transactions and minting events.

  • Pausing operations when irregularities are identified.

These enhancements would provide an added layer of security, making the contract more robust and better equipped to handle unexpected situations while maintaining smooth operations.

Frameworks and Methodologies

This security assessment was conducted in alignment with recognised penetration testing standards, methodologies and guidelines, including the NIST SP 800-115 – Technical Guide to Information Security Testing and Assessment , and the Penetration Testing Execution Standard (PTES) , These assets provide a structured foundation for planning, executing, and documenting technical evaluations such as vulnerability assessments, exploitation activities, and security code reviews. Hacken’s internal penetration testing methodology extends these principles to Web2 and Web3 environments to ensure consistency, repeatability, and verifiable outcomes.

Disclaimer