A.History and Development of the Company We trace our history to 1996, when the first version of the Opera-branded web browser was launched. Since that time, we have been focused on developing consumer internet products centered on web browsing, content discovery and related services for a global user base. Opera Limited is an exempted company with limited liability incorporated in March 2018 in the Cayman Islands. Opera Limited is a holding company with no substantive operations of its own, and our principal operations are conducted through our subsidiaries, including in particular Opera Norway AS, a private limited liability company incorporated under the laws of Norway. We acquired Opera Norway AS and its subsidiaries in November 2016, which included the business of developing and distributing Opera’s mobile and PC web browsers and certain related products and services. Our principal executive offices are located at Vitaminveien 4, 0485 Oslo, Norway, and our telephone number is +47 23 69 24 00. Our principal website is www.opera.com. Information contained on, or accessible through, our website is not part of, or incorporated by reference into this annual report. Our agent for U.S. federal securities law purposes is Cogency Global Inc, 122 East 42nd Street, 18th Floor, New York, NY 10168. Our ADSs have been listed on the Nasdaq Global Select Market under the symbol “OPRA” since July 27, 2018. We completed our initial public offering in August 2018 and a follow-on public offering in September 2019. In October 2023, a pre-IPO shareholder completed a secondary public offering of ADSs, from which we did not receive any proceeds. On December 6, 2024, we effected a one-for-two consolidation of our ordinary shares approved by shareholders on December 3, 2024. Concurrently, the ratio of ordinary shares to ADSs was changed from two-to-one (2:1) to one-to-one (1:1). Following the share consolidation, our authorized share capital is $50,000 divided into 250,000,000 ordinary shares with a par value of $0.0002 per share. As of the date of this annual report, 89,880,513 ordinary shares were outstanding. The SEC maintains a website at www.sec.gov that contains reports and other information filed electronically with the SEC through its EDGAR system. Our annual report and other filings are available on this website and on our investor relations website at investor.opera.com. Information contained on, or accessible through, our investor relations website is not part of, or incorporated by reference into this annual report. See “Item 10. Additional Information—H. Documents on Display” for further information. B.Business Overview Opera is a global pioneer in consumer internet software, providing a diversified portfolio of high-performance web browsers and adjacent digital services to our large and engaged user base of over 284 million average MAUs in the fourth quarter of 2025. Founded in 1995 and headquartered in Oslo, Norway, we have transitioned from browser developer to multi-faceted platform offering a range of products and services that include PC and mobile browsers, our Opera Gaming portals and development tools, Opera News content platforms, Opera Ads platform, as well as a number of AI and web3 products and services, such as MiniPay and Opera AI, to a global 23 Table of Contents user base. Opera launched one of the first PC browsers in 1996 and introduced the world’s first full web browser for mobile phones in 2002. Since then, Opera has remained an innovator in the browser space, launching features including tabbed browsing, data savings, PC-mobile data sync, and numerous features focused on privacy and security, including ad blocking and a built-in VPN. We provide a unique variety of carefully tailored browsers, made for consumers who seek an alternative to those provided as default on their devices. Our browsers had approximately 258 million average MAUs in the fourth quarter of 2025. We differentiate ourselves by delivering purpose-built browser experiences that integrate features like native AI assistants, built-in VPNs, and gaming-centric optimizations directly into the interface for both desktop and mobile platforms, reducing user reliance on third-party extensions and creating a higher barrier-to-entry ecosystem. The browser is an increasingly strategic application—often serving as the access point for content, e-commerce, AI, gaming and fintech activities on the internet, and Opera is utilizing this strategic position to launch and scale new products and offerings. Our operating model is built upon a high-engagement distribution layer—our browsers—which provides the foundation for our integrated monetization engine. We generate revenue primarily through search distribution and partner monetization, digital advertising via our proprietary Opera Ads platform, and emerging product-led initiatives such as content and web3 services. Our Products and Users It all starts with the browser, the on-ramp to users’ online and AI experiences. We leverage the browser to expand our digital advertising business, Opera Ads, and as a launch pad for additional services, including Opera Gaming, Opera News and our web3 offerings. Browsers Our browser family serves as the core distribution and engagement layer for our entire ecosystem. We provide a suite of specialized browsers, including our flagship Opera One browser, which features a modular design and Opera AI, our native browser AI. For the gaming community, Opera GX provides a distinctive and customizable aesthetic along with unique hardware optimizers and integrations to reach a high-value, highly engaged demographic. Opera One and Opera GX are available on a wide variety of platforms including desktop computers, Android and iOS devices. Opera Air, which was introduced in 2025, targets users seeking a mindfulness experience, with neural beats to promote focus and imagination. In late 2025, we introduced Opera Neon, a premium, subscription-based agentic AI browser designed for productivity-oriented users, which automates complex web-based tasks. Over time, we plan to introduce some of the innovations we develop for Opera Neon to Opera AI, and with that, to our full suite of browsers. In mobile-first markets, Opera Mini remains a critical tool for data-conscious users due to its proprietary compression technology. The primary value proposition of our browsers is to provide a faster, more secure, and highly personalized gateway to the internet that exceeds the capabilities of standard pre-installed browsers. We distribute these products primarily through direct downloads on PC and major app stores on mobile. In the fourth quarter of 2025, the total MAUs of our browsers reached an average of approximately 258 million, with Opera GX contributing 34 million MAUs. Advertising Platform Opera Ads is our proprietary advertising ecosystem that connects advertisers with our massive audience reach across both owned-and-operated surfaces and partner inventory. It supports a wide array of formats, including native, video, and e-commerce-specific placements. The platform serves as a critical link between our user engagement and revenue, allowing us to monetize user discovery and intent. As an internet company focused on browsers, we can leverage the closed-loop environment of the browser to capture interest, context and intent. We are able to create value and utility for the user throughout their online journey, unlike many advertising platforms which rely on third-party signals and cookies. With the growth of high value users and the scale of our audience extension offering, we are becoming an increasingly relevant partner for advertisers. Opera Gaming Building on the success of Opera GX, Opera has developed a community of gamers and game creators. This included creating the Opera Gaming division that provides GameMaker, a 2D gaming development platform. The focus of Opera Gaming is to continue to grow the user base of Opera GX and build increased functionality within and outside the Opera GX browser, using GameMaker. GameMaker provides game creators with a complete set of tools to create games for any platform. Opera News Leveraging our user base and innovation capability, we launched the Opera News service in January 2017. Opera News is our personalized news discovery and aggregation service. The service is featured prominently as part of our browsers, and also made available as a standalone app and website. These apps operate under both the Opera News and Apex brands. By providing AI-powered 24 Table of Contents news and content recommendations, we have increased both user activity and the amount of time users spend in our ecosystem. Opera News curates and intelligently recommends news, articles, videos and other online content that may be of interest to each individual user. Users can conveniently access this content through real-time intelligent ranking, top news and push notification features. When using a product powered by our recommendation engine, people can efficiently discover, engage with and share online content that appeals to them. Our Opera News content platform reached an average audience of approximately 40 million MAUs in the fourth quarter of 2025 through Opera browsers, our dedicated Opera News apps, websites, and partner integrations. Web3 Our web3 efforts are spearheaded by MiniPay, a self-custodial stablecoin wallet initially integrated directly into our mobile browsers and now available as a standalone app for Android and iOS users. MiniPay is positioned as a lightweight solution for emerging markets, allowing users to send, receive, and save digital dollars using a phone number as an identifier. Built on the Celo blockchain, MiniPay facilitates peer-to-peer transactions at low or de minimis cost and supports cUSD, USDC, USDT and Tether Gold. MiniPay has experienced rapid growth, reaching approximately 14 million activated wallets and 420 million cumulative transactions by March 2026. Users In the fourth quarter of 2025, our total MAUs reached an average of approximately 284 million, of which approximately 86 million were PC users and 198 million were mobile users. Our strategy continues to focus on shifting our user mix toward high-ARPU developed markets, which has successfully driven our annualized ARPU to $2.49 in the fourth quarter of 2025. For more information about our users, see “Item 5. Operating and Financial Review and Prospects—A. Operating Results—User Metrics.” Our total monthly advertising reach, including both active users of our applications, other users of our content portals, as well as individuals served by our Opera Ads audience extension, exceeded over half a billion by December 2025. Our Partners Our revenue is primarily driven by performance advertising and strategic partnerships for intent-based query monetization. Advertising Revenue Our advertising revenue is generated from inventory on our apps and websites, as well as from inventory on third-party apps and websites. We work closely with large, global e-commerce and online travel agencies, as well as strong local brands globally. The value of these partnerships continues to rise through increased user engagement with these popular services within our browsers, as well as our audience extension offering. We earn revenue from transactions initiated by our directed users via links provided on our Speed Dial homepage and other advertisements, typically in the form of a defined share of the revenue generated by these service providers. We have established relationships with leading digital advertising platforms. We allow these digital advertising platforms to display their advertising demand in our browsers, content apps and websites where we recognize revenue based on the amounts we are entitled to receive from such advertising partners. We also sell selected premium advertising placements, such as full-screen banners, interstitials, videos, sponsored articles and notifications to global and local advertisers. Our Opera Ads platform has a large and continuous focus on audience extension and is able to seamlessly integrate with both Opera’s owned and operated inventory and selected premium partner inventories supplied by companies such as Google, AppLovin, Adtechnacity, Vungle and others. The Opera advertising platform caters to the world’s largest advertisers, brands, platforms, agencies, and e-commerce partners across the Americas, Asia, Europe, Africa, and the Middle East. A majority of our customers are operating within gaming, sports, and e-commerce verticals. Query Revenue We partner with internet search providers such as Google and Yandex and have worked closely with them for over 25 and 15 years, respectively. These partnerships ensure a native integration of search technology for our users and enhance the visibility of our brand. We share the revenue generated by our search partners when our users initiate queries within the URL bar, default search page or search boxes embedded in our PC and mobile browsers. We recently updated our reporting to reflect query revenue, which supplements traditional search revenue with newer intent based query monetization that is often AI targeted. Under this model, we earn revenue from a broader set of partners that we may promote in response to a user prompt within our browsers. We have had a search distribution agreement with Google since 2001. We entered into our current search distribution agreement with Google in 2012 and have extended the term of that agreement multiple times, most recently until December 31, 2026 for markets outside of the U.S. We have entered into a separate search distribution agreement with Google for the U.S. market with a term 25 Table of Contents extending to January 31, 2027. We have had a search distribution agreement with Yandex since 2007. Effective January 1, 2025, we renewed our relationship with Yandex with a new three-year agreement with Yandex in UAE. Our agreements with Google and Yandex are subject to customary events of default, including failure to make payments, material breach, liquidation, as well as other termination trigger events as provided therein. Our relationship and cooperation with our search providers may be impacted by any material investigations and restructurings relating to these search providers. See “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business, Strategy and Operating Environment—A substantial portion of our revenues is derived from users’ query activities within Opera browsers” of this annual report. See Note 3 to our consolidated financial statements included elsewhere in this annual report for a breakdown of revenue by activity and geography. Our Marketing Channels We partner with ad agencies, influencers, game affiliation networks, device manufacturers, mobile network operators and others to promote and distribute our products. We have long-term relationships with device manufacturers to ensure cost-efficient and reliable distribution benefiting both these distribution partners and us. We partner with mobile network operators in Africa for joint marketing campaigns, including the provision of free or reduced cost browsing to the consumer for a limited time. In addition, we partner with game affiliation networks to promote Opera GX. We have also partnered with Riot Games to promote Opera GX as the official browser of the League of Legends World Championships. For the majority of our products and services, the main source of new users is brand awareness of our products and the “word-of-mouth” from our large user base. The trust and reliance that our users place in us is a key growth driver of our business, since prospective users that hear positive feedback from their friends and colleagues about our products and services are more likely to try them. We have run influencer marketing campaigns to raise awareness and gain trust and mind-share among key target demographics. We also run promotional campaigns around global events, such as sporting events, to further engage users and drive adoption. In 2025, organic installs were our most important channel for new user acquisition, representing approximately 83% of our new smartphone users. In parallel, we cooperate with industry partners to promote our products. In 2025, approximately 7% of new smartphone users originated from our paid online promotions. Our products are available through our official website, www.opera.com, as well as Google Play, Apple’s App Store, and other online distribution channels. Our go-to-market strategy for Opera Ads includes both a managed service for large-scale advertisers and a self-serve platform for small-to-medium enterprises, allowing us to scale our advertising reach across a diverse client base. Our Technology Technology is key to our success as it enables us to innovate, improve our users’ experience and operate our business more efficiently. We have a track record of pioneering functionalities that then become the new standard in the browsing world. Our technology team is composed of highly skilled engineers, computer scientists and technicians whose expertise spans a wide range of areas. As of December 31, 2025, we employed a team of approximately 444 engineering and data analytics personnel. These staff members engage in building our technology platforms and developing new Opera products and services, with our core browser and AI assisted browsing development located mainly in Poland and Sweden, and our other products developed mainly in Poland, China, Sweden and the United Kingdom. AI & Agentic Browsing Opera AI, formerly known as Aria, is a browsing AI based on our own Composer AI engine. Composer is LLM agnostic - meaning it uses multiple LLM models, including OpenAI’s GPT, Google’s Gemini, and self-hosted open source models like LLAMA. Composer selects the best model for the Opera AI user’s query. Composer also enables premium subscribers to select which model they wish to use. Our Composer engine architecture is fully modular and easily expandable, which allows access to multiple external data sources like weather as well as webpages on the Internet, and also allows Composer to integrate functionality like image and video generation and understanding, as well as voice generation and understanding. Composer can access, understand and generate many file formats including xls, ods, pdf, doc, mp3, mp4 and others. Composer is capable of tooling, grounding and embedding to drive new experiences, enabling Opera AI to make its own decisions, spin up virtual, cloud-hosted computers, first-research-then-build web applications, host and share content, and even compose a set of “researchers” — with a head researcher orchestrating the process. 26 Table of Contents Partly due to Composer’s multi LLM approach, our Opera Deep Research Agent achieved one of the best results in benchmark testing of AI researching agents on the market. Composer is a privacy-first AI engine, with keys managed by the client and the end-user. Content Recommendation Our content discovery and recommendation platform provides our users with personalized news, audio, videos and other online content. We leverage our existing user base and cutting-edge technologies, such as LLMs and AIGC, to develop our AI-powered content discovery and a multi-scenario/multi-modal/multi-objective recommendation platform that we integrate into a variety of our products and services. Our content recommendation platform evaluates a large volume of potentially correlated data points between each item of online content and each individual user to provide personalized content recommendations of high interest to our users in real time. Cloud Compression Technologies Our compression technologies are built into our apps to optimize data traffic and connection times for our users. These technologies allow our browsers to load web pages faster by downloading less data. Our Mini browser compresses web content by up to 90%, providing a good web browsing experience even on the most limited mobile data networks. Network Infrastructure We operate a distributed network infrastructure designed to support our global operations. Our infrastructure consists of company-owned servers hosted in third-party data centers and integrated with cloud-based resources, enabling us to scale computing and storage capacity efficiently in response to changes in demand. We use automated provisioning and orchestration tools to manage capacity and support service availability across different devices, operating systems, carriers and network environments. As of December 31, 2025, we owned 5,388 servers in seven data centers located in the Netherlands (two locations), the United States, Canada, Nigeria, Iceland and Singapore, with a total connectivity bandwidth of approximately 1.54 Tbps max throughput and 360 Gbps daily peak. The data center in Iceland features an NVIDIA DGX SuperPOD with 248 H100 GPUs capable of delivering approximately 1 exaflops of FP8 AI performance, which serves as the basis for our expanding AI services. Our Investments in Unconsolidated Entities We hold minority investments in the following entities: •OPay Ltd., an investee in which we currently hold a 9.5% ownership interest, is a privately-held fintech company operating in emerging markets across Africa and Asia. It provides digital financial services, including payments, transfers, savings and lending products, and offers point-of-sale services to agents and acquiring services to merchants. •MiniPay Fund, a venture fund managed by Verda Ventures established to invest in MiniPay ecosystem companies and projects, where we are one of several investors, holding a 27.4% ownership interest as of December 31, 2025. MiniPay is our stablecoin-based, self-custodial wallet built on the Celo blockchain. We invested $1.25 million in this venture fund in 2024 and an additional $2.5 million in 2025. As of December 31, 2025, we had an outstanding capital commitment of $6.25 million. Our primary objective with the investment is to support the development and adoption of products and services around MiniPay, alongside other investors. •nHorizon Innovation (Beijing) Software Ltd. (“nHorizon Innovation”) is an associate in which we have a 29.1% ownership interest. It generates income from providing technical and management services to nHorizon Infinite (Beijing) Software Limited (“nHorizon Infinite”). nHorizon Infinite, which was our joint venture until mid-2023, supports Chinese app developers in monetizing their apps internationally through advertising. User Privacy and Safety The vitality and integrity of our user base is the cornerstone of our business. We dedicate significant resources to the goal of strengthening our user base through developing and implementing programs designed to protect user privacy, promote a safe environment, and ensure the security of user data. We also implement unique features in our products and services to protect users’ online digital presence, such as a free, no-log VPN service, a premium, paid VPN service for enhanced protection, native ad blocking and anti-tracking options. Our privacy statements seek to describe our data use practices and how privacy works on our platforms in a user-friendly manner. We provide users with adequate notice as to what data is being collected and undertake to manage and use the data collected in accordance with applicable laws. We consider the protection of the personal privacy of each of our users to be of paramount importance. 27 Table of Contents We continuously strive to prevent unauthorized use, loss or leak of user data. In addition, we use a variety of technical and organizational measures to protect the data with which we are entrusted, including, for example, encryption of personal data, and web application firewalls to protect against potential attacks or unauthorized access. We have privacy and security teams dedicated to the ongoing review and monitoring of data protection practices, including penetration testing, auditing, and carrying out data privacy impact assessments. Competition We operate in highly competitive and rapidly evolving markets, including web browsers, digital advertising, content distribution, and digital wallets. Competition in these markets is intense, dynamic, and influenced by rapid technological change, shifting user behavior, and evolving regulatory and platform environments. For a detailed discussion of risks related to competition, see “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business, Strategy and Operating Environment—We face intense competition across our products and services which could materially adversely affect our business.” Seasonality See “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business, Strategy and Operating Environment—Our revenue and results of operations are subject to seasonal and other fluctuations.” Intellectual Property We regard our patents, copyrights, service marks, trademarks, trade secrets and other intellectual properties as critical to our success. We rely on patents, trademarks, copyrights and trade secret protection, as well as non-competition, confidentiality, and license agreements with our employees, customers, partners and others to protect our intellectual property rights. Despite our precautions, it may be possible for third parties to unlawfully obtain and use our intellectual properties without authorization. Furthermore, the validity, enforceability and scope of protection of intellectual property rights in internet-related industries are uncertain and still evolving. As of December 31, 2025, we had active registrations or pending applications for our trademarks in over 90 countries and for our logos in over 80 countries. Opera has a patent portfolio that includes more than 20 patents issued in the United States as well as certain international patent registrations. In addition, as of December 31, 2025, we had hundreds of registered domain names related to our businesses. Regulations Norwegian Regulations on Intellectual Property Rights Norway adheres to key international agreements for the protection of intellectual property rights, hereunder the Paris Convention for the Protection of Industrial Property, Berne Convention, Universal Copyright Convention of 1952, the Rome Convention and the TRIPS agreement. The main acts governing intellectual property rights in Norway are the Patents Act of December 15, 1967, Designs Act of March 14, 2003, Trademarks Act of March 26, 2010, Copyrights Act of June 15, 2018, and Marketing Act of January 9, 2009. The Trade Secrets Act of March 27, 2020, protects trade secrets. Trademarks, designs and patents must be registered by applying to the Norwegian Industrial Property Office, or the NIPO, in order to be valid in Norway. Patent applications which have been granted at the European Patent Office can be validated in Norway by applying to the NIPO. Regulations on Data Protection and Information Security The principal data protection legislation in Norway is the Personal Data Act of June 15, 2018, no. 38. The Personal Data Act implements 2016/679/EU - General Data Protection Regulation, or GDPR, in its entirety. The purpose of the act is to protect natural persons from violation of their right to privacy through the processing of personal data. Broadly speaking, the GDPR applies to the processing of personal data conducted by companies established in the European Economic Area, or EEA, and to the processing of personal data of data subjects in the EEA, where the processing is linked to offering services to such data subjects or monitoring their behavior. A significant number of the users of our products are in the EEA and we also serve many of our users from our business establishments in Norway and Ireland, and consequently our processing of the personal data of such users is subject to the GDPR. Since the GDPR came into effect in 2018, courts and data protection authorities have enforced its requirements strictly and levied significant fines against various technology companies for violations. Decisions by such authorities, as well as guidance from the 28 Table of Contents European Data Protection Board have repeatedly emphasized that international transfers of personal data should be subject to heightened scrutiny. Furthermore, regulatory decisions and guidance, as well as related litigation, underscore that digital advertising and artificial intelligence are areas of particular attention for privacy authorities. The United States is also adopting new regulations related to data protection. For example, in 2024, the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (PADFAA) was enacted in the United States. PADFAA prohibits “data brokers” from disclosing certain categories of personal data, defined as “personally identifiable sensitive data,” to foreign adversaries. Similarly, in 2025, the U.S. Department of Justice implemented a rule entitled “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” (DOJ Rule) which prohibits U.S. companies from transferring certain classes of sensitive personal data of U.S. persons to foreign companies that are owned or controlled in designated countries, including China. Both the PADFAA legislation and the DOJ Rule could introduce uncertainties for parts of our advertising business, particularly regarding data-sharing dynamics with U.S. based partners. In recent years many additional jurisdictions, including Brazil, Kenya, Nigeria, India and China, have enacted or updated data privacy or data localization laws. Similarly, several states of the U.S. have passed or are debating their own privacy laws. The precise requirements of each law vary widely, though we see some general trends towards more regulatory oversight, especially of data-driven businesses like ours, and increased focus on service and data localization. We anticipate continued developments in data protection, privacy and data localization rules in various countries, which will continue to affect our business and impact our products and services. See “Item 3. Key Information—D. Risk Factors—Risks Related to Technology, Intellectual Property, Data Protection and Cybersecurity—Evolving privacy and consumer protection laws could adversely affect our business” of this annual report. EU Regulations on Cyber Resilience, Artificial Intelligence and Digital Services The Cyber Resilience Act (CRA), which entered into force on December 10, 2024, addresses cybersecurity standards for digital products distributed in the EU, including web browsers. The CRA requires that browsers be designed, developed and produced in line with the certain cybersecurity requirements, that extensive security related documentation be created and maintained, assessment procedures be performed, and that security vulnerabilities be reported. The requirements of the CRA will be phased in gradually through December 2027. New laws, regulations, policies, and international accords relating to artificial intelligence and digital service, are being developed and formalized in Europe and the U.S. For example, the EU Artificial Intelligence Act includes specific transparency and other requirements for general purpose AI systems and the models on which those systems are based. In addition, the White House's Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence devises a framework for the U.S. government, among other things, to regulate private sector use and development of certain foundation models. The EU’s Digital Markets Act (DMA), which entered into force on November 1, 2022, is intended to ensure a higher degree of competition in European digital markets. The DMA prohibits companies designated as “gatekeepers” and providing core platform services from engaging in certain kinds of self-preferencing behaviors, resulting in increased implementation of browser choice screens and other similar effects that support a healthier competitive landscape for independent companies like Opera. Regulations Relating to Content Recommendation Our Opera News content discovery and recommendation platform is available in a wide variety of markets worldwide. In recent years, there has been an increased emphasis on the veracity of online news reports, with the increasing social expectation that content platforms and aggregators will take steps to prevent the dissemination of fake news. Moreover, a number of countries have adopted regulatory regimes for news aggregation services requiring local registration or licensing, in some cases enabling more effective governmental restrictions on their citizens’ access to certain categories of information. Other countries have adopted legislation expanding publishers’ copyright entitlements on digital platforms including search engines, social media and content recommendation platforms. Various countries, including Australia and Indonesia, for example, have adopted laws which afford publishers of digital media the right to receive payment for use of their content in search results or content recommendations. In 2019, the European Union adopted Directive (EU) 2019/790 on copyright and related rights in the Digital Single Market, which gives press publications more direct control over the re-use of their content and also tasks online content sharing platforms, which host user-generated content, with certain duties related to preventing their users from violating copyright of others. In short, content aggregation is becoming increasingly regulated, and we anticipate that we will be subject to an increasingly diverse and fragmented regulatory environment over time. Regulations Relating to the Crypto Industry MiniPay is our stablecoin-based, self-custodial wallet built on the Celo blockchain. The regulatory environment for crypto assets is becoming increasingly diverse and fragmented. On December 30, 2024, European Union Regulation (EU) 2023/1114 on markets in crypto-assets, or MiCA, went into force. While MiCA does not directly apply to MiniPay, the regulation has impacted ecosystem participants. For example, certain crypto exchanges have limited access in the EEA to stablecoin tokens that fall under the MiCA e-money token definitions but do not hold the required e-money token issuance authorization. Additionally, under European Union 29 Table of Contents Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets, MiCA crypto assets service providers are obliged to collect information about the originator of the incoming crypto transactions from non-custodial wallets. European Economic Sanctions The European Union adopted certain economic sanctions following the 2014 invasion and purported annexation of Crimea in Council Regulation (EU) 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine, or the EU Regulation. Norway, as a member of the EEA, has incorporated the EU Regulation’s economic sanctions into its domestic law in the Norwegian Sanctions Act. Since 2014 and in light of Russia’s continuing aggression in Ukraine, the European Union has amended the EU Regulation with various additional packages of economic sanctions and accordingly additional sanctions have in due course likewise been incorporated into Norwegian domestic law. For example, on December 16, 2022, the European Union adopted an amendment to the EU Regulation prohibiting the provision of “advertising services” to legal persons, entities or bodies established in Russia, and therefore we have subsequently terminated all advertising contracts with customers in Russia among other actions. Likewise, on June 24, 2024, the European Union adopted an amendment to the EU Regulation requiring companies in the EU to use “best efforts” to ensure their respective non-EU subsidiaries also comply with the sanctions. The European Union, as well as other jurisdictions including the United States, have continued to periodically adopt more and additional sanctions from time to time. Human Rights In July 2022, the Norwegian Transparency Act came into force. To promote respect for basic human rights and decent working conditions, the Transparency Act imposes a duty on Norwegian companies to publish certain information regarding how they work to ensure basic human rights and decent working conditions, both in their own businesses as well as in their supply chains. In accordance with the act, Opera carries out due diligence assessments of the risks associated with Opera’s business of potential violation of basic human rights or decent working conditions by Opera, its suppliers, or its business partners. The results of these due diligence assessments are reported and made public annually on Opera’s website. C.Organizational Structure The chart below summarizes our corporate structure as of the date of this annual report and identifies all our principal subsidiaries and their places of incorporation: _______________ (1)0.01% is held by another Opera group entity. (2)30% is held by a nominee shareholder. D.Property, Plants and Equipment Our corporate headquarters is located in Oslo, Norway. Our principal technical development facilities are located in Wroclaw, Poland, Dundee, Scotland, Beijing, China and both Linköping and Gothenburg, Sweden. We also maintain offices in several other countries, including Singapore, Nigeria, Ireland, France, Germany, Spain, South Africa and Kenya. 30 Table of Contents Our servers are hosted in data centers in the Netherlands, the United States, Canada, Nigeria, Iceland and Singapore. These data centers are owned and operated by third-party providers with which we have hosting and colocation agreements that typically have initial terms of one to three years and are renewable.