this was a CC, they allow you to use only dice rolls for entropy, and still don't enforce minimum rolls on Mk3 or older Mk4 firmware. you can even still so a single dice roll for a temp seed.
oh that's surprising then, and sounds like a bug. The docs actually say it has to be at least 99 dice rolls. @NVK https://coldcard.com/docs/paranoid/#generating-seed-words-with-256-bits-of-entropy-by-dice-rolls