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A false sense of security
The mandatory introduction of e-invoicing in Belgium is often approached as a technical and administrative formality. However, there is a more important discussion to make: efficiency without security is merely a faster way to lose money. While the Peppol network is known as a secure "digital highway" for invoicing, the security of that highway in practice depends entirely on the checks performed at the entry ramps.
The promise of Peppol lies in automation and standardization via XML files. Because these files are processed directly and often automatically into accounting software, the role of human intervention changes fundamentally. While a PDF could still be visually checked for logos or suspicious bank account numbers, this is impossible with an XML file. Consequently, security does not end with the technology of the network itself; it begins with identity and access control.
The vulnerability of registration and access
The risk of invoice fraud in Peppol usually does not occur during the transport of the invoice, but much earlier: during registration on the network. Peppol does not automatically check the intentions of those entering the digital highway. That responsibility lies with the software platforms and the so-called Access Points (APs) that grant companies access.
When a platform does not verify the identity of a sender with absolute certainty, a weak link is created. Fraud can occur when a party registers using an existing enterprise number without a valid mandate. If a provider's onboarding is based solely on a VAT number without strict verification, the risk of identity fraud remains.
KYC as the foundation of security
To guarantee the financial integrity of SMEs, a strict Know Your Customer (KYC) principle is essential. This is not an administrative hurdle, but the foundation of a reliable network.
Secure onboarding starts with the identification of a legal representative. Using tools such as itsme or a live identity check, an irrefutable link is established between three crucial elements:
The person: A verified identity.
The company: The official link to the enterprise.
The mandate: The explicit authority to digitally represent the company.
If any of these elements are missing, access is denied. This approach prevents unauthorized individuals from gaining rights to manage or manipulate invoicing flows.
The role of the gatekeeper and internal control
Not every platform manages its own access to Peppol. Operating an in-house Access Point, however, is a significant factor in maintaining control. It ensures that identity verification, mandate validation, and security rules are managed centrally, without fragmentation or grey areas in responsibility.
In addition to external access, internal governance within the SME is also crucial. Digital processes require explicit rights management: who is allowed to send invoices, who receives them, and who can initiate payments? By clearly defining roles and mandates and linking every action to a verified identity, full traceability is achieved. This is a basic requirement for detecting and correcting errors or fraud in a timely manner.
Conclusion: Security as a guiding principle
Modernization without built-in security poses a risk to business continuity. For Belgian SMEs, the true value of the e-invoicing mandate lies not just in the speed of the transaction, but in the certainty that the process is manageable and protected. By putting identity and mandates at the center, e-invoicing becomes more than just a legal requirement, it becomes a secure lever for digital growth.