Regulatory updates - Pakistan

On September 24, 2025, the Federal Board of Revenue (FBR) published Notification S.R.O. 1852(I)/2025, superseding the previous notification from August 1, 2025. The new regulation sets revised deadlines for registration, testing, and issuance of e-invoices for sales tax registered persons.

The requirements apply to public companies, importers, and businesses with varying annual turnover, as well as other specified groups. All affected entities must integrate their hardware and software with the FBR’s computerized system through a licensed integrator or PRAL (Pakistan Revenue Automation (Pvt) Limited) and begin issuing electronic invoices according to the updated schedule.

Implementation deadlines

Key deadlines for registration, testing, and issuance of e-invoices are as follows:

• Companies with turnover above Rs. 1,000,000,000 (approx. EUR 3,200,000), all public companies and importers:
  • Registration: October 15, 2025
  • Testing: October 25, 2025
  • Issuance of e-invoices: November 1, 2025
• Companies with turnover between Rs. 100,000,000 (approx. EUR 320,000) and Rs. 1,000,000,000 (approx. EUR 3,200,000):
  • Registration: October 25, 2025
  • Testing: October 31, 2025
  • Issuance: November 15, 2025
• Companies with turnover below Rs. 100,000,000 (approx. EUR 320,000):
  • Registration: November 15, 2025
  • Testing: November 25, 2025
  • Issuance: December 1, 2025
• Individuals and associations with turnover exceeding Rs. 100,000,000 (approx. EUR 320,000):
  • Registration: October 10, 2025
  • Testing: October 25, 2025
  • Issuance: November 1, 2025
• Other registered persons:
  • Registration: December 10, 2025
  • Testing: December 25, 2025
  • Issuance: December 31, 2025

All invoices must be issued through the FBR system to ensure validity and compliance with input tax adjustment rules. Penalties for non-compliance remain in effect as per the Sales Tax Act, 1990.

On August 1, 2025, the Federal Board of Revenue (FBR) issued Notification S.R.O. 1413(I)/2025, mandating e-invoicing for specific categories of sales tax registered persons.

The regulation applies to public companies, importers, and businesses with an annual turnover exceeding Rs. 1,000,000,000 (approx. EUR 3,200,000), as well as other specified groups. These entities must complete registration and testing for integration with FBR’s computerized system through a licensed integrator or PRAL (Pakistan Revenue Automation (Pvt) Limited), and begin issuing e-invoices by the deadlines outlined in the official notification.

Implementation deadlines

Key deadlines for registration, testing, and issuance of e-invoices are as follows:

• Public companies, large importers, and companies with turnover above Rs. 1,000,000,000 (approx. EUR 3,200,000) declared in sales tax returns for the last 12 months:
  • Registration: August 10, 2025
  • Testing: August 25, 2025
  • Issuance of e-invoices: September 1, 2025
• Companies with turnover between Rs. 100,000,000 (approx. EUR 320,000) and Rs. 1,000,000,000 (approx. EUR 3,200,000), and qualifying individuals/associations:
  • Registration: September 10, 2025
  • Testing: September 30, 2025
  • Issuance: October 1, 2025
• Companies with turnover below Rs. 100,000,000 (approx. EUR 320,000):
  • Registration: October 10, 2025
  • Testing: October 30, 2025
  • Issuance: November 1, 2025
• Other registered persons:
  • Registration: November 10, 2025
  • Testing: November 30, 2025
  • Issuance: December 1, 2025

Requirements and penalties

Invoices issued outside the FBR system are invalid and may affect input tax adjustments. Under the Sales Tax Act, 1990, monetary penalties for non-compliance start at approximately Rs. 500,000 (approx. EUR 1,600) per instance and can escalate to approximately Rs. 3,000,000 (approx. EUR 9,600) for repeated violations.

On June 20, 2025, Pakistan’s Federal Board of Revenue (FBR) announced a further extension to the e-invoicing integration deadlines under Rule 150Q of the Sales Tax Rules, 2006. This marks the second revision to the original schedule set forth in SRO 709(I)/2025.

Under the latest directive, corporate-registered persons were required to integrate with the FBR’s computerized system by July 1, 2025, while non-corporate registered persons now have until August 1, 2025, to comply. These deadlines replaced the previously revised dates of June 1 and July 1, respectively.

The integration must be completed through a licensed integrator or via PRAL (Pakistan Revenue Automation Limited), as part of the government’s broader initiative to digitize and streamline tax compliance.