If I look at microinverter data I see the microinverters 'wake up' as much as an hour before dawn and start reporting a Voc of 25-50% of Voc @ STC. Maybe half an hour later they reach start voltage and start producing a watt or two of power near Vmp, suggesting that the irradiance perhaps needs not to even reach as much as 10 w/m^2 to get substantially close to Voc @ STC. In other words the Voc to irradiance curve is extremely steep at very low irradiance and then transitions to a (comparatively) extremely low slope thereafter.
That said, you need some irradiance for voltage, so I believe it is correct to say that if min temp always occurs in the darkness of night then max irradiance and min temp are extremely unlikely to be contemporaneous. The moon (or even, say, cloud reflected light from human sources) is only a small fraction of a watt/m^2. So, for example, if one had temperature data that excluded all times post-dusk to pre-dawn, I believe one would be justified and code compliant to use that.