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Blog

Why EIP-4337's Mempool is a New Frontier for MEV

Account Abstraction's public UserOperation pool isn't just a UX upgrade—it's a new, granular attack vector for MEV searchers. We break down the risks beyond the traditional tx mempool.

introduction
THE NEW MEMPOOL

Introduction

EIP-4337's alternative mempool is not just a user experience upgrade; it is a fundamental re-architecting of transaction flow that creates a new, permissionless market for MEV.

UserOperation Mempool: The core innovation of EIP-4337 is a separate, parallel mempool for UserOperations, which are meta-transactions for smart accounts. This segregates intent expression from execution, creating a new surface for value extraction.

Intent-Based MEV: Unlike the traditional transaction-ordering MEV in Ethereum's base mempool, the UserOperation mempool enables intent-based MEV. Searchers like Eden Network and Flashbots now compete to fulfill complex user intents, not just reorder simple transfers.

Bundler Economics: The new economic actor, the Bundler, aggregates and submits UserOperations. Their profit is the delta between the user's fee and the actual execution cost, creating a permissionless PBS (Proposer-Builder Separation) model at the application layer.

Evidence: The Pimlico and Alchemy bundler services already process millions of UserOperations, demonstrating the scale of this new transaction flow and the associated extractable value for searchers and builders.

thesis-statement
THE MEMPOOL SHIFT

Core Thesis: Granularity is the New Attack Surface

EIP-4337's UserOperation mempool fragments transaction flow, creating new, granular MEV opportunities that bypass traditional searcher models.

UserOperations are not transactions. They are intent declarations that require off-chain bundlers to simulate, package, and submit them. This creates a pre-execution simulation layer where value is extracted before a transaction hits the canonical mempool.

Bundlers are the new block builders. Unlike Ethereum validators, any entity can run a bundler. This commoditizes block building at the application layer, creating a competitive market for order flow between bundlers like Stackup, Alchemy, and Pimlico.

MEV shifts from execution to simulation. Searchers must now compete in the intent discovery phase, analyzing UserOperations for profitable bundles before they are finalized, a process tools like Rated and Flashbots SUAVE are already adapting to.

Evidence: The proliferation of Paymaster services, which subsidize gas for specific applications, demonstrates the bundler-as-a-service business model and creates direct financial incentives to capture and prioritize certain UserOperation streams.

A NEW FRONTIER FOR MEV

Mempool Comparison: Legacy vs. EIP-4337

Contrasts the transaction execution environments that define MEV extraction and user experience in Ethereum's current state versus its account-abstraction future.

Feature / MetricLegacy Mempool (EOA)EIP-4337 UserOperation Mempool

Transaction Originator

Externally Owned Account (EOA)

Smart Contract Wallet (Bundler)

Atomic Execution Scope

Single transaction

Multi-op UserOperation bundle

Pre-Execution Simulation

Basic gas estimation

Full validateOp & callData simulation via eth_call

MEV Searcher Access

Direct (Public Mempool)

Indirect (Must win Bundler auction)

Base Fee Payment Asset

ETH only

Any ERC-20 (via Paymasters)

Permissionless Block Building

All validators

Bundlers only (specialized nodes)

Typical Latency to Inclusion

< 12 seconds

< 30 seconds (extra bundling layer)

Frontrunning Surface

Entire transaction calldata

Limited to bundle ordering; internal ops are simulated & fixed

deep-dive
THE NEW FRONTIER

Deep Dive: The Attack Vectors in the Alt Mempool

EIP-4337's alt mempool introduces new, non-EVM state that sophisticated actors are already exploiting for profit.

UserOperation mempool is public. The alt mempool for EIP-4337 UserOperations is not private. Searchers and builders monitor it directly, just like the standard mempool. This creates a new data feed for MEV extraction before transactions reach the canonical chain.

Bundler ordering is the new block builder. The bundler's role is analogous to a block builder. The entity that wins the right to include a UserOperation bundle dictates transaction order, enabling frontrunning and sandwich attacks within the account abstraction layer itself.

Paymasters are a centralization risk. Reliance on a third-party paymaster to sponsor gas creates a single point of failure. A malicious or compromised paymaster can censor transactions or drain sponsored funds, a risk not present in native EOA transactions.

Simulation griefing is a novel attack. Searchers can spam the network with malicious UserOperations designed to fail simulation. This wastes bundler resources, increases latency, and creates a denial-of-service vector that degrades the entire system's reliability.

Evidence: The Pimlico and Alchemy bundler teams have documented these vectors, with simulation spam being a primary operational cost. Real-world MEV bots on networks like Polygon already parse alt mempools for profitable opportunities.

risk-analysis
EIP-4337 MEV LANDSCAPE

Risk Analysis: Who Bears the Burden?

Account abstraction's permissionless mempool shifts MEV risk from users to builders and bundlers, creating new attack surfaces.

01

The Problem: Mempool Poisoning

The public UserOperation mempool exposes pending intents, enabling frontrunning and denial-of-service attacks. Malicious actors can spam the network with revert-only operations or gas price manipulation to censor or extract value from legitimate users.

  • Key Risk: Intent-based transactions are more complex and vulnerable to pre-execution analysis.
  • Impact: User experience degrades as transaction failure rates and latency increase.
~100%
Intent Exposure
+300ms
Attack Window
02

The Solution: Private Order Flows

Bundlers like Stackup, Alchemy, and Biconomy must operate private mempools or use MEV-boost style relays to protect UserOperations. This mirrors the evolution seen in Ethereum's block building ecosystem post-PBS.

  • Key Benefit: Shifts risk from end-users to professional, capitalized bundlers.
  • Benefit 2: Enables off-chain auction mechanisms for fair ordering, similar to CowSwap or UniswapX.
90%+
Flow Privatized
0
User-Side MEV
03

The New Burden: Bundler Economics

Bundlers bear capital risk for prefunding gas and operational risk for selecting profitable bundles. They become the primary target for time-bandit attacks and must manage complex simulation logic to avoid losses.

  • Key Risk: A malicious UserOperation can drain a bundler's stake via a revert-with-gas loop.
  • Mitigation: Requires robust reputation systems and stake slashing, akin to EigenLayer for restaking security.
$1M+
Stake Required
-100%
Rogue Bundle Loss
04

The Arbiter: Paymasters as MEV Sinks

Paymasters that sponsor gas become central MEV distribution hubs. They can extract value by bundling transactions and selling order flow, similar to Robinhood's payment for order flow model, but on-chain.

  • Key Risk: Centralization pressure on who can afford to run a profitable paymaster service.
  • Opportunity: Creates a new subsidy layer for dapps, abstracting gas costs entirely for users.
10-30%
Potential Yield
Oligopoly
Risk Profile
future-outlook
THE NEW MEV BATTLEGROUND

Future Outlook: Mitigations and the Long Game

EIP-4337's UserOperation mempool creates a novel, permissionless attack surface for MEV, forcing a strategic shift from transaction-level to intent-level extraction.

The mempool is permissionless. The UserOperation mempool is a public good with no native censorship, creating a free-for-all for searchers. This contrasts with private order flows and centralized RPCs that dominate today's MEV.

Bundlers are the new validators. The bundler role centralizes execution risk, becoming the primary target for MEV extraction and bribery. This mirrors the validator/proposer dynamic in Proof-of-Stake Ethereum.

Intent abstraction enables new attacks. Searchers will exploit the time delay between simulation and execution to front-run or sandwich aggregated user intents, a vector impossible in vanilla Ethereum.

Mitigation requires new infrastructure. Solutions like SUAVE's encrypted mempool or Flashbots' SUAVE are prerequisites, not options. The ecosystem needs dedicated PBS for bundles and reputation systems for bundlers.

Evidence: The proliferation of ERC-4337 bundler services from Stackup, Alchemy, and Pimlico demonstrates the immediate commercial race to control this new MEV gateway.

takeaways
EIP-4337'S MEMPOOL

Key Takeaways for Builders

The UserOperation mempool is not just a new transaction type; it's a fundamental re-architecting of the transaction supply chain, creating a new MEV surface.

01

The Problem: The Unbundled Searcher

Traditional MEV searchers operate on atomic bundles. EIP-4337's UserOperations are non-atomic, breaking their models. This creates a new role: the Bundler, who aggregates UserOps into a single on-chain transaction.

  • New Revenue Stream: Bundlers capture fees and can extract value from the ordering of UserOps.
  • Fragmented Liquidity: Searchers must now compete across hundreds of independent Bundler mempools, not one public mempool.
100+
Bundlers
Fragmented
Liquidity
02

The Solution: Intent-Based Order Flow

UserOperations express user intent (e.g., "swap X for Y at a good price"), not explicit execution. This mirrors the shift seen in UniswapX and CowSwap.

  • MEV Capture Shift: Value accrues to the party that best fulfills the intent, not just the fastest searcher.
  • Privacy Boost: Intents can be fulfilled off-chain via solvers, reducing frontrunning surface. This is the Flashbots SUAVE vision, but native to account abstraction.
Intent-Based
Paradigm
Off-Chain
Execution
03

The Frontier: P2P vs. Centralized Mempools

Ethereum's vision is a permissionless P2P mempool for UserOps. In practice, early dominance by Stackup, Alchemy, and Biconomy points to centralized aggregation.

  • Relayer Risk: Centralized Bundlers become trusted order-flow gatekeepers, a single point of failure/censorship.
  • Builder Opportunity: Decentralized Bundler networks (like Rated, EigenLayer AVS) are the next infra battle. Think Flashbots for EIP-4337.
Centralized
Early Risk
AVS
Opportunity
04

The New Stack: Paymasters as MEV Sinks

Paymasters sponsor gas fees, enabling gasless UX. They pay for on-chain execution, making them the ultimate fee sink.

  • Order Flow Auction: Paymasters can auction sponsored UserOp bundles to the highest-bidding Bundler, creating a formal OFA market.
  • Subsidy Arbitrage: Protocols can subsidize specific actions (e.g., onboarding) and extract value via Paymaster-Bundler collusion or rebates.
Gasless UX
Driver
OFA Market
Created
05

The Cross-Chain Angle: Account Abstraction Unlocks Universal Intents

A UserOperation can trigger actions on other chains via bridges like LayerZero or Across. The Bundler becomes a cross-chain orchestrator.

  • Unified Liquidity: MEV can be extracted across the liquidity fragmentation of L2s by bundling cross-chain swaps.
  • Complex Arbitrage: Atomic cross-chain arbitrage, previously near-impossible, becomes feasible via a single user signature.
Cross-Chain
Arbitrage
Unified
Liquidity
06

The Build Checklist: What to Monitor

For builders, the key is to instrument for this new landscape.

  • Metrics: Track Bundler centralization (Gini coefficient), Paymaster adoption rates, and cross-chain UserOp volume.
  • Integration Points: Build Bundler clients, solver networks for intent fulfillment, or Paymaster strategies that capture value from sponsored flows.
Gini Coef.
Metric
Solver Nets
Opportunity
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