Regulatory updates - Pakistan

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.

On April 30, 2025, Pakistan's Federal Board of Revenue (FBR) issued an official extension to the previously announced e-invoicing integration deadlines under Rule 150Q of the Sales Tax Rules, 2006.

According to the new directive, corporate-registered persons must integrate by June 1, 2025, while non-corporate registered persons must comply by July 1, 2025.

This move follows the initial deadlines set by SRO 709(I)/2025 on April 22, 2025, which mandated integration from May 1 and June 1, respectively.

The extension allows registered businesses to align their systems with FBR’s digital platform through a licensed integrator or PRAL (Pakistan Revenue Automation Limited), reinforcing the country’s ongoing shift toward a more transparent and automated tax infrastructure.