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account-abstraction-fixing-crypto-ux
Blog

The Future of Transaction Sequencing is a Bundler Cartel

Account abstraction's promise of seamless UX is undermined by its core infrastructure. The economic incentives of ERC-4337 bundlers will lead to cartelization, exclusive order flow, and rampant MEV extraction at the user's expense.

introduction
THE CARTEL THESIS

Introduction

The economic logic of block building will inevitably consolidate transaction sequencing into a small, dominant cartel of bundlers.

The bundler is the block builder. In an account abstraction (ERC-4337) future, the entity that sequences user operations (UserOps) for inclusion on-chain controls the mempool. This role mirrors the block builder in today's MEV supply chain, creating a direct path to market power.

Sequencing is the new mining. The profit motive for orderflow will drive consolidation, just as it did for Proof-of-Work mining pools. The most efficient bundlers, like Pimlico or Stackup, will capture dominant market share by offering the best execution and highest subsidies.

The cartel is a feature, not a bug. A stable, predictable sequencing cartel reduces fragmentation, enabling complex cross-domain intents. This is the necessary infrastructure for systems like UniswapX and Across Protocol to function reliably at scale.

Evidence: Look at Solana. Jito Labs, by controlling a majority of block production through its client and MEV services, demonstrates the natural endpoint of this economic logic. The same forces apply to the bundler network.

thesis-statement
THE MARKET STRUCTURE

The Inevitable Cartel

The economic logic of block building and MEV extraction guarantees the consolidation of transaction sequencing into a dominant cartel.

The builder market consolidates. The competitive advantage in block building is capital efficiency and data access, not decentralization. Entities like Flashbots and Jito Labs win by operating private orderflow connections and sophisticated MEV strategies, creating insurmountable moats.

Decentralization is a tax. A truly decentralized sequencer set, as envisioned by early rollup teams, sacrifices extractable value and latency. The profit-maximizing equilibrium is a small consortium that coordinates to maximize MEV, mirroring the miner extractable value (MEV) cartelization seen in Ethereum's PBS.

The cartel is a feature. This consolidation provides predictable finality and liveness for applications, which matters more to end-users than the myth of permissionless sequencing. The cartel becomes a regulated, high-availability utility, similar to AWS regions.

Evidence: Look at L1. Ethereum's Proposer-Builder Separation (PBS) created a builder oligopoly within three months. The top three builders consistently produce over 80% of blocks. This pattern will repeat in rollup sequencing, accelerated by shared sequencing layers like Espresso and Astria.

market-context
THE WILD WEST

The Current Bundler Landscape: Pre-Cartel Formation

Today's bundler market is a fragmented, permissionless, and low-margin competition that cannot scale.

Permissionless competition is unsustainable. The ERC-4337 standard allows anyone to run a bundler, creating a commodity market where the only differentiator is price. This drives user operation fees to near-zero, eliminating profitability for operators and disincentivizing infrastructure investment.

Fragmentation destroys user experience. Users must trust dozens of independent bundlers like Pimlico, Stackup, and Alchemy for reliable inclusion. This creates a single point of failure landscape where one bundler's downtime breaks entire dApps, unlike the redundancy of Ethereum's base layer.

The economic model is broken. Bundlers earn only priority fees from user operations, a revenue stream orders of magnitude smaller than the MEV extraction available to L1 block builders. This misalignment guarantees that the most sophisticated actors will eventually dominate and consolidate the market.

Evidence: The top three bundlers process over 60% of all ERC-4337 volume, demonstrating early centralization pressure despite the permissionless design. This is a precursor to formal cartelization.

THE CARTELIZATION THESIS

Bundler Market Concentration & Vertical Integration

Comparison of bundler business models and their implications for market structure, censorship resistance, and MEV capture in the ERC-4337 ecosystem.

Metric / FeatureIndependent BundlerWallet-Integrated BundlerVertical Stack (Appchain/Sequencer)

Market Share (Current)

~15% (e.g., Pimlico, Stackup)

~80% (e.g., Alchemy, Biconomy)

<5% (e.g., zkSync, Arbitrum Stylus)

Primary Revenue Source

User-paid priority fees + MEV

Wallet subscription/API fees

Sequencer profit + L1 settlement profit

Censorship Resistance

MEV Capture & Redistribution

Yes (to user via auctions)

Yes (to wallet/operator)

Yes (to sequencer/validator set)

Avg. UserOp Inclusion Time

< 2 seconds

< 1 second

~12 seconds (L2 block time)

Relies on Public Mempool

Protocol-Level Integration

ERC-4337 Node

ERC-4337 Node + Wallet SDK

Native L2 Execution Client

Long-Term Viability Risk

High (commoditized service)

Medium (wallet lock-in)

Low (captive appchain traffic)

deep-dive
THE INCENTIVE TRAP

The Slippery Slope: From Service to Cartel

The economic design of rollup sequencing naturally consolidates power, transforming a neutral service into a revenue-extracting cartel.

Sequencers capture maximal value. As the sole block producer for a rollup, the sequencer controls transaction order, inclusion, and MEV extraction. This position generates profits from fees, arbitrage, and front-running, creating a powerful centralizing force.

Decentralization is a tax, not a feature. Projects like Arbitrum and Optimism propose decentralized sequencing via staking or committees. This adds latency and cost, which users and applications reject for the speed of a single, efficient operator.

The cartel forms via vertical integration. Dominant players like Flashbots' SUAVE or Lido's potential expansion will bundle sequencing across chains. They leverage existing stake and liquidity to offer 'better' execution, locking in market share.

Evidence: Look at L2 revenue. Over 90% of Arbitrum and Optimism sequencing is controlled by their founding entities. The profit per sequenced transaction far exceeds the cost, proving the model's extractive nature.

case-study
FROM FRAGMENTATION TO CARTEL

Case Study: The Intent-Based Parallel

The evolution of transaction ordering from simple mempools to intent-based systems mirrors the centralizing forces now shaping rollup sequencing.

01

The Problem: The Mempool is a Free-For-All

Traditional transaction submission is a low-level, adversarial game. Users broadcast raw txs to a public mempool, exposing them to frontrunning and MEV extraction. This creates a poor UX where execution is unpredictable and users must overpay in gas to win blockspace.

  • Inefficient Discovery: Users cannot express desired outcomes, only specific actions.
  • Adversarial Environment: Bots scan for profitable opportunities at the user's expense.
  • Fragmented Liquidity: Execution is siloed to a single chain's validator set.
$1B+
Annual MEV
~12s
Avg. Latency
02

The Solution: Intents Abstract Execution

Intent-based architectures (e.g., UniswapX, CowSwap, Across) let users declare what they want, not how to achieve it. A solver network competes to fulfill the intent optimally, abstracting away complexity.

  • Better Prices: Solvers tap into off-chain liquidity and cross-chain venues for optimal routing.
  • MEV Protection: Users get a guaranteed outcome; solvers internalize the MEV risk.
  • Chain Abstraction: The intent can be fulfilled across any chain or liquidity source.
10-50%
Price Improvement
~500ms
Solver Competition
03

The Parallel: Solver Networks → Bundler Cartels

Just as intent solvers consolidated into a few dominant networks (e.g., CowSwap's solver set, UniswapX's fillers), rollup sequencing is converging on cartels. The economic logic is identical: economies of scale in block building and MEV extraction favor centralization.

  • Natural Oligopoly: The most capital-efficient builders win, creating shared sequencer sets like Astria, Espresso, Radius.
  • Vertical Integration: Major players (e.g., Coinbase with Base) will internalize sequencing for their rollups.
  • Regulatory Attack Surface: A cartel of a few sequencers is a clearer target than 1,000+ validators.
3-5
Major Sequencers
>80%
Market Share
04

The Endgame: Protocol-Enforced Cartels (SUAVE)

The logical conclusion is a protocol that formalizes and governs the cartel. SUAVE aims to be a decentralized block builder/sequencer marketplace, but its success would create a canonical cartel at the protocol layer.

  • Centralized Coordination: Even if decentralized in name, governance and stake will concentrate.
  • Universal Order Flow: Becomes the default destination for all chains and intents.
  • Infrastructure Monopoly: Control over sequencing is control over the network's economic spine.
1
Dominant Market
$10B+
Captured Value
counter-argument
THE CARTEL PROBLEM

Counter-Argument: Can't We Just Build More Bundlers?

Increasing bundler count fails to solve the fundamental economic and technical centralization of transaction sequencing.

Bundlers are not validators. Adding more bundlers does not decentralize the sequencer role. The winning bidder for a block space bundle holds a temporary monopoly on ordering, creating a per-block cartel.

Economic centralization is inevitable. The MEV extraction race favors the largest, best-capitalized operators like Flashbots and BloXroute. Smaller bundlers get outbid and excluded from profitable blocks.

Technical barriers create oligopoly. Running a competitive bundler requires low-latency infrastructure and sophisticated MEV software, mirroring the Ethereum validator centralization problem seen with Lido.

Evidence: On Ethereum L2s today, over 90% of blocks are produced by the single, official sequencer. A multi-bundler future replicates this model with a rotating cast of the same few players.

risk-analysis
FROM ABSTRACT RISK TO CONCRETE LOSS

The User Impact: A Taxonomy of Harm

Centralized control over transaction ordering creates predictable, exploitable outcomes that directly harm users and protocols.

01

The MEV Tax: A Universal Slippage

Bundlers extract value from every swap, transfer, and liquidation by frontrunning and sandwiching transactions. This is not a fee for service, but a rent extracted from user intent.

  • Costs users ~$1B+ annually across Ethereum and L2s.
  • Distorts price discovery by inserting toxic order flow.
  • Acts as a regressive tax, disproportionately impacting small trades.
~$1B+
Annual Extract
5-50+ bps
Per-Trade Tax
02

Censorship as a Service

A cartel can blacklist addresses or transactions based on political pressure or commercial interests, undermining blockchain neutrality.

  • Protocols like Tornado Cash become un-usable if major bundlers collude.
  • Creates regulatory single points of failure for OFAC compliance.
  • Enables rug-pull facilitation by censoring warning transactions.
100%
Block Inclusion Power
0
User Recourse
03

The Latency Arms Race

To avoid MEV extraction, users and searchers are forced into expensive, wasteful infrastructure races, centralizing advantages.

  • Requires expensive private mempools (e.g., Flashbots Protect, bloXroute).
  • Creates a two-tier system: pro users with bots vs. normies in the public pool.
  • Wastes energy and capital on zero-sum priority gas auctions.
~500ms
Advantage Window
10-100x
Cost Multiplier
04

Protocol Capture & Stagnation

Bundlers can prioritize their own or partner protocol transactions, killing fair launch and innovation.

  • A UniswapX order flow could be delayed to favor a bundler-owned AMM.
  • New DeFi primitives fail if they can't pay for priority inclusion.
  • Creates a pay-to-play ecosystem that mirrors web2 app store monopolies.
>51%
Stake for Control
$0
Barrier to Entry
05

The Systemic Risk of Liveness Failure

Reliance on a few centralized bundler operators creates a critical liveness vulnerability for entire rollup ecosystems.

  • A coordinated outage could halt an L2 like Arbitrum or Optimism.
  • Forces L2s into risky governance interventions to restore function.
  • Contradicts the core value proposition of decentralized settlement.
~3-5
Critical Entities
Minutes
To Halt Chain
06

Privacy as a Premium Feature

Transaction privacy reverts to a paid service for the wealthy, as bundlers can deanonymize and exploit public order flow.

  • Only protocols with encrypted mempools (e.g., Aztec, FHE chains) offer real privacy.
  • Normal wallet activity becomes a free data feed for bundler trading desks.
  • Erodes fungibility by making certain transaction patterns toxic.
$0
Public Privacy
High $
Private Cost
future-outlook
THE CARTELIZATION

Future Outlook: The Regulatory Trigger

The natural economic endgame for transaction sequencing is a regulated cartel of institutional bundlers.

Regulatory pressure is inevitable for permissionless sequencers. The SEC's stance on staking-as-a-service and OFAC compliance for validators creates a precedent. A bundler cartel emerges not from collusion, but from regulatory arbitrage, where compliant entities capture market share.

Institutional capital demands compliance. Entities like JPMorgan's Onyx or Fidelity Digital Assets will not route orders through anonymous, permissionless sequencers. They will demand KYC'd, audited, and licensed bundler infrastructure, creating a bifurcated market.

Technical decentralization becomes a liability. The censorship-resistant sequencing of SUAVE or Espresso becomes a regulatory target, not a feature, for mainstream financial activity. This forces a split between compliant L2s and permissionless 'dark pool' chains.

Evidence: The migration of MEV-Boost relays towards OFAC compliance shows the path. Over 90% of Ethereum blocks are now OFAC-compliant, demonstrating that regulatory pressure directly shapes infrastructure centralization.

takeaways
THE BUNDLER CARTEL THESIS

Key Takeaways for Builders and Investors

The race for transaction ordering is creating a new, centralized power layer in the rollup stack. Here's how to navigate it.

01

The Problem: MEV is the Real Product

Bundlers don't make money on gas. Their profit is extracted from cross-domain MEV and order flow auctions. The business model incentivizes centralization into a few dominant players like Jito Labs and Flashbots.\n- Revenue Source: >90% from MEV, not fees.\n- Risk: Censorship and transaction blacklisting become trivial.

>90%
MEV Revenue
~5
Dominant Players
02

The Solution: Build on a Neutral Sequencing Layer

Protocols like Espresso Systems and Astria offer shared, decentralized sequencer networks. This abstracts away the bundler cartel risk for rollup developers.\n- Key Benefit: Sovereignty over your chain's block space.\n- Key Benefit: Inherits liveness and censorship resistance from a decentralized validator set.

Shared
Security
Sovereign
Execution
03

The Hedge: Integrate Intent-Based Architecture

Move logic off-chain. Systems like UniswapX and CowSwap use solvers who compete in auctions to fulfill user intents, bypassing the public mempool and its MEV entirely.\n- Key Benefit: Better prices via solver competition.\n- Key Benefit: User transactions are private and non-frontrunnable.

No MEV
For Users
Auction-Based
Execution
04

The Investment: Vertical Integration Wins

The endgame is a vertically integrated stack. Look for entities that control the application, its bundler/sequencer, and its settlement layer (e.g., a dedicated rollup). This captures the full value chain.\n- Key Benefit: Maximizes extractable value and user experience.\n- Key Benefit: Creates defensible moats against generic bundler cartels.

Full Stack
Control
Defensible
Moat
05

The Metric: Time-to-Finality is the New TPS

Forget transactions per second. In a multi-chain world, the critical metric is time-to-guaranteed-finality across domains. This is what EigenLayer and Near's Fast Finality layer are solving.\n- Key Benefit: Enables real cross-chain composability.\n- Key Benefit: Reduces liquidity fragmentation risk.

<2s
Target Finality
Composability
Unlocks
06

The Reality: Regulatory Capture is Inevitable

Centralized sequencer sets operated by entities like Coinbase (Base) or Kraken will be the first targets for OFAC compliance demands. This creates a bifurcated market: compliant chains vs. credibly neutral chains.\n- Key Benefit: (For Builders) Clear compliance path for some use cases.\n- Key Risk: Forces ideological and technical fragmentation of the ecosystem.

Bifurcated
Market
OFAC
First Target
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Bundler Cartels Are the Future of Transaction Sequencing | ChainScore Blog