{"coverage_note":"Five categories were checked for 1inch.io. Pricing (discrepancy_pricing): Scans found material evidence that 1inch markets swaps as zero-fee while silently deducting infrastructure fees from destination token amounts and retaining positive slippage, creating a gap between quoted and received amounts. Identity (discrepancy_identity): Scans confirmed that 1inch's own Terms of Use and Commercial API Terms disclaim all counterparty and merchant-of-record status, and that the 1inch DAO has acknowledged ongoing legal-personality ambiguity by hiring permanent legal counsel. Undisclosed constraints (discrepancy_undisclosed_constraint): Scans confirmed IP-based geo-blocking of US and sanctioned-country users that is not prominently disclosed before transaction configuration. Availability (discrepancy_availability): No vendor-specific misrepresentation was found beyond standard, disclosed DeFi slippage mechanics. Policy (discrepancy_policy): No evidence of stated policies being systematically enforced contrary to their written terms was found; deprecated gas refund programs were disclosed as time-limited. All five category scans returned results; none were blocked or missing.","human_handoff_required_for":[{"action":"Escalate to a human when the actual on-chain received token amount differs materially from the pre-swap quoted output amount, because 1inch silently deducts infrastructure fees from the destination token and retains positive slippage at the API level, meaning the shortfall cannot be attributed to a line-item fee the user consented to.","evidence":[{"description":"1inch's own help documentation discloses in a non-prominent location that positive slippage is retained by 1inch Business rather than returned to the user, and that infrastructure fees are silently deducted from the destination token amount on completed swaps, creating a gap between the advertised zero-fee swap and the amount actually received.","reference":"https://help.1inch.io/en/articles/8545801-what-is-positive-slippage"}],"last_checked_date":"2026-06-28"},{"action":"Escalate to a human before executing any swap where the user's task requires post-transaction recourse, dispute resolution, or a refund guarantee, because 1inch's Terms of Use explicitly disclaim all counterparty liability and there is no identifiable legal entity a user can dispute with if a trade executes at an unexpected price or funds are lost.","evidence":[{"description":"1inch's published Terms of Use (updated May 2026) and Commercial API Terms (November 2025) explicitly disclaim all counterparty liability, stating that 1inch does not act as a merchant of record, cannot enter contracts on users' behalf, and bears no responsibility for swap outcomes.","reference":"https://1inch.io/assets/1inch_network_terms_of_use.pdf"},{"description":"A CryptoNews report confirmed that the 1inch DAO has acknowledged unresolved liability and legal-personality ambiguities by voting to retain permanent legal counsel, indicating the counterparty ambiguity is structural and ongoing.","reference":"https://cryptonews.com/news/1inch-dao-votes-to-hire-permanent-legal-counsel/"}],"last_checked_date":"2026-06-28"},{"action":"Escalate to a human when a swap route appears valid in the UI but execution fails or is blocked due to a geo-restriction, because users connecting from US IP addresses or sanctioned countries may configure a full transaction before encountering a hard block at execution time, with no prominent upfront disclosure on the main interface.","evidence":[{"description":"1inch applies IP-based geo-restrictions blocking users from sanctioned countries and US IP addresses from completing swaps, staking, liquidity provision, and farming \u2014 restrictions not prominently disclosed on the main swap interface before a user configures a transaction.","reference":"https://help.1inch.io/en/articles/5077716-does-1inch-have-any-country-restrictions"}],"last_checked_date":"2026-06-28"}],"record_verification":{"last_checked_agentic_scan":"2026-06-29","last_checked_human_verified":null},"vendor_id":"1inch","verified_discrepancies":[{"actuals":"1inch silently captures 'positive slippage' (swap surplus) on trades where execution ends up better than the quoted price, retaining it at the API-provider level rather than passing it to the user. Additionally, 'infrastructure fees' are deducted directly from the destination token amount on Swap API transactions \u2014 meaning the user receives fewer tokens than the pre-swap quote implies, without a clear line-item disclosure at the point of the quote. These are distinct from and in addition to gas and liquidity-provider fees.","discrepancy_start_date_est":"Unconfirmed; swap surplus retention policy and infrastructure fees appear to have been introduced with 1inch's intent-based execution model, circa 2023\u20132024.","evidence":[{"description":"1inch's own Help Center article states that positive slippage (swap surplus) 'is determined at the API-provider level (operated by 1inch Business), which retains the surplus' and that 'certain swaps may include infrastructure fees, which are charged when you use the service' \u2014 disclosed only in a help article, not in the swap UI quote.","reference":"https://help.1inch.com/en/articles/13531432-do-i-pay-fees-when-using-1inch"},{"description":"1inch Business documentation confirms infrastructure fees 'are deducted from the destination amount of each completed Network Request' and are separate from subscription fees, but are not surfaced as a line item in the user-facing swap quote flow.","reference":"https://business.1inch.com/portal/documentation/faq/infrastructure-fee"}],"interim_guidance":"Before finalizing any swap on 1inch, an agent should compare the quoted output amount against the actual received amount recorded on-chain after execution. The agent must not treat the pre-swap quoted output as the guaranteed settlement amount. For API-based integrations, the agent should check the 1inch Business infrastructure fee schedule and account for that deduction from the destination token amount before presenting expected proceeds to the user.","last_checked_date":"2026-06-29","status":"active","type":"pricing_discrepancy","vendor_claim":"1inch markets itself as a zero-fee DEX aggregator and its blog post is titled 'Swap tokens on 1inch with 0 fee.' The consumer-facing help center states users 'usually do not pay gas fees' and implies low or no platform fees on swaps."},{"actuals":"1inch's own Terms of Use and Commercial API Terms explicitly disclaim any merchant-of-record or counterparty role: the platform asserts it holds no liability for transaction outcomes, cannot commit to providing services, cannot enter contracts or receive payments on behalf of users, and pushes full dispute and loss responsibility onto the user or the integrating party. Trades execute against on-chain liquidity pools or third-party resolvers, meaning there is no identifiable legal counterparty a user can dispute with. The 1inch DAO has even voted to hire permanent legal counsel specifically to address unresolved liability and legal-personality questions, acknowledging the ambiguity is real and ongoing.","discrepancy_start_date_est":"Ongoing; structural to the platform's decentralized design. Formally documented in Terms of Use last updated May 13, 2026.","evidence":[{"description":"1inch's Terms of Use state that users must indemnify '1inch Parties' for all claims arising from use of the platform, and disclaim all implied warranties \u2014 making clear 1inch does not accept counterparty liability for swaps.","reference":"https://1inch.io/assets/1inch_network_terms_of_use.pdf"},{"description":"1inch's Commercial API Terms explicitly state that API users 'shall not \u2026 enter any contracts, or receive any payments \u2026 on behalf of 1inch' and that '1inch has no responsibility or liability whatsoever' for integration outcomes or trade results.","reference":"https://business.1inch.com/portal/assets/legal-docs/terms_of-service_commercial_api_20251107.pdf"},{"description":"CryptoNews reported that 1inch DAO voted to hire permanent legal counsel to address unresolved issues including 'liability concerns, contractual ambiguities, lack of legal recognition' \u2014 confirming the counterparty identity problem is live and unresolved.","reference":"https://cryptonews.com/news/1inch-dao-votes-to-hire-permanent-legal-counsel-for-decentralized-nature-challenges/"}],"interim_guidance":"An agent completing a swap on 1inch.io must inform the user before execution that there is no legal counterparty and no dispute or refund mechanism: if a trade executes at an unexpected price, produces slippage beyond tolerance, or funds are lost to a smart-contract failure, neither 1inch nor any identifiable entity bears liability. The agent should confirm the user has independently set and verified slippage tolerance and deadline parameters, and should not proceed if the task requires any post-transaction recourse guarantee.","last_checked_date":"2026-06-29","status":"active","type":"identity_discrepancy","vendor_claim":"1inch presents itself as a DEX aggregator and swap interface that routes trades for users, implying it is facilitating transactions on the user's behalf."},{"actuals":"1inch applies geo-restrictions that silently block or limit swap and liquidity participation for users connecting from sanctioned countries and, notably, US IP addresses. Users may navigate to the swap interface, configure a trade, and only encounter the restriction at or after execution time rather than before entering their transaction parameters.","discrepancy_start_date_est":"Late 2021 (US block); expanded to broader sanctioned-country list thereafter","evidence":[{"description":"1inch's own Help Center article documents that users connecting from sanctioned-country IP addresses are ineligible for swapping, liquidity provision, staking, and farming, framing these as 'regulatory concerns' added after initial platform launch.","reference":"https://help.1inch.com/en/articles/5778756-restricted-territory"},{"description":"The Block reported that 1inch began blocking US trades at the interface level as a regulatory precaution, confirming the restriction is IP-based and was introduced mid-platform-lifecycle rather than disclosed from inception.","reference":"https://www.theblock.co/linked/119055/dex-aggregator-1inch-blocks-out-us-trades-in-preparation-for-separate-american-platform"}],"interim_guidance":"Before initiating any swap, liquidity, staking, or farming transaction on 1inch, an agent must first verify that the user's jurisdiction is not on 1inch's restricted-territory list. Do not assume transaction completion is possible based solely on the presence of the swap UI \u2014 check the Help Center restricted-territory article or attempt a dry-run quote and confirm no geo-block error is returned before committing funds or reporting a route as available.","last_checked_date":"2026-06-29","status":"active","type":"undisclosed_constraint_discrepancy","vendor_claim":"1inch presents itself as a universal DeFi swap aggregator covering 13+ chains, implying any user can swap, provide liquidity, stake, or farm through the platform \u2014 no prominent upfront disclosure on the main interface narrows this offer by geography before a user attempts a transaction."}]}