In a PEPPOL environment, each company is identified by a PEPPOL Participant Identifier (PEPPOL ID), which functions as its digital trade identity. The PEPPOL ID is needed to receive any e-document through the PEPPOL network. 

PEPPOL IDs typically consist of a numerical code of two parts such as 0208:0123456789, if we take a standard Belgian company as an example. 

In the case of Belgium, many Belgian companies had PEPPOL IDs automatically created via the national Hermes platform, which served as a temporary government platform until 31 December, 2025, to help businesses unable to directly use PEPPOL send digital structured invoices.

In several cases, companies were unaware that their PEPPOL ID existed in the first place and were left unclaimed or unmanaged. 

This situation resulted in a vulnerability window in which malicious actors could attempt to exploit dormant or unclaimed PEPPOL IDs and attempt to pose as the legitimate business itself. 

In the UAE context, where organizations are increasingly focused on cash preservation and supplier payment accuracy, the misuse of a digital identity could have immediate financial consequences. Fraudulent invoices processed through automated systems may directly impact liquidity positions, particularly in organizations with high transaction volumes or centralized shared service centers.

PEPPOL operates through certified Access Points (APs) that onboard businesses and route e-invoices through its network. One of the key risks identified by the report highlighted risks associated with weak identity verification (KYC/KYB) during onboarding.

If onboarding controls at the AP level are insufficient, a malicious actor could attempt to register using a legitimate company name or a valid VAT number.

If successful, any invoice generated by the malicious actor would then travel through the certified e-invoicing infrastructure and produce a “successful delivery” status, thereby appearing compliant.

Despite the delivery confirmation being merely evidence of a technical transmission between APs, without validation of the invoice content or its commercial legitimacy, some companies have equated it to an authenticity corroboration and allowed these invoices to be processed through their standard Procure-To-Pay (P2P) processes. 

This risk is particularly relevant in the current UAE environment, where many organizations are streamlining procure-to-pay processes and increasing automation to drive efficiency. While automation improves speed and reduces manual intervention, it also increases dependency on upstream data integrity. Without reinforced validation controls, erroneous or fraudulent invoices may flow through systems more quickly, amplifying financial exposure before detection.

It is, however, important to note that these risks don’t lie in PEPPOL’s encryption architecture itself but in the insufficient governance framework by its various participants.

As recently as October 2025, a company called Invoicely used by 250,000 businesses globally, accidentally exposed a repository in its cloud infrastructure^[2] with over 178,000 sensitive and financial documents, including Personally Identifiable Information (PII), which is one of the most critically protected categories of data globally.

PII data can be leveraged by malicious actors for a multitude of purposes including identity theft, social engineering, and targeted invoice fraud to name a few. 

This situation did not result from a sophisticated cyberattack on Invoicely’s infrastructure but a simple misconfiguration of one storage component as “public read” in their Amazon Web Services instance by Invoicely themselves.

While this relates, strictly speaking, to online-generated invoicing as opposed to e-invoicing meant via PEPPOL, most e-invoicing providers are cloud-based (Software as a Service (SaaS)) and therefore exposed to this risk.