Pakistan E-Invoicing Update: FBR Sets July 1 Deadline for Electronic Invoice Compliance
Learn about Pakistan’s latest FBR e-invoicing mandate requiring FMCG businesses to generate and transmit electronic invoices by 1 July 2025. Find out who is affected, how integration works, and what steps businesses must take to stay compliant.
Countdown to Compliance: Pakistan’s E-Invoicing Deadlines in 2025
On 22 April 2025, Pakistan’s Federal Board of Revenue (FBR) issued Notification S.R.O. 709(I)/2025, a pivotal development in the country’s move towards digitising tax compliance. Under this notification, electronic invoicing (e-invoicing) has become mandatory for a wide category of businesses dealing in fast-moving consumer goods (FMCG). Both corporate and non-corporate registered persons must integrate their systems with the FBR’s computerised platform for the generation and transmission of electronic invoices via licensed integrators or Pakistan Revenue Automation Limited (PRAL).
Recently, deadlines have been postponed with one month. They are now set at:
- Corporate registered persons must comply by 1 July 2025
- Non-corporate registered persons have until 1 August 2025
With these staggered timelines, the FBR aims to support a smooth transition, but businesses must act fast to avoid non-compliance penalties. The Sales Tax Rules, 2006 (specifically Rule 150Q, as amended) provide the legal and technical framework underpinning this rollout.
From Paper to Platform: A Brief History of E-Invoicing in Pakistan
Pakistan has steadily been evolving its tax administration system through digitisation, and e-invoicing has become a cornerstone of this transformation. The push for digital compliance began in earnest with Notification No. 1525(I)/2023, which came into force on 1 February 2024. This earlier directive required importers, manufacturers, distributors, dealers, wholesalers, and wholesaler-cum-retailers of FMCG (Fast-Moving Consumer Goods) to transmit sales tax invoices electronically.
This effort was part of the broader strategy by the FBR to promote transparency, reduce tax evasion, and enable real-time data reporting. Prior to the 2025 notification, the obligation was narrower in scope and served as a pilot to test the infrastructure and readiness of affected sectors. With the issuance of S.R.O. 709(I)/2025, the FBR has expanded and formalised the requirement, leaving no ambiguity about its future intentions: a fully digitised tax ecosystem.
How to Generate and Transmit: E-Invoicing in Practice
So, how exactly does e-invoicing work in Pakistan under the new rules?
Under the new framework, all registered persons covered by the notification must digitally generate and transmit sales tax invoices through integrated software systems. These systems must connect to the FBR's central computerised system either through licensed integrators or via PRAL.
The process is governed by the amended Chapter XIV of the Sales Tax Rules, 2006, and requires the following key steps:
- The e-invoicing system must generate, record, encrypt, and transmit invoice data in real time.
- Each invoice must bear a unique FBR invoice number, digital signature, and a QR code, and be formatted according to FBR specifications.
- A complete set of invoice fields must be populated, including seller and buyer details, registration numbers, product description, tax rates, H.S. codes, discounts, and references to the applicable SRO.
- The e-invoice data is stored securely and used to auto-fill Annex-C of the sales tax return, easing compliance for registered entities.
In the case of power or internet outages, invoices must be clearly marked as “offline” and uploaded within 24 hours of system restoration.
Who’s on the Hook? Entities Caught in the E-Invoicing Net
Who’s on the Hook? Entities Caught in the E-Invoicing Net
S.R.O. 709(I)/2025 specifically targeted certain categories within the Fast-Moving Consumer Goods (FMCG) sector, mandating electronic invoicing for the following entities:
- Importers of FMCGs
- Manufacturers of FMCGs
- Wholesalers, dealers, and distributors of FMCGs
- Wholesaler-cum-retailers engaged in bulk import and supply of FMCGs to retailers
These businesses were required to integrate their invoicing systems – both hardware and software – with the Federal Board of Revenue's (FBR) computerized system through licensed integrators or the Pakistan Revenue Automation Limited (PRAL). Additionally, each outlet or Point of Sale (POS) system had to be registered, with the integration status visibly displayed, including the phrase "Integrated with FBR" and system registration details.
However, it's important to note that subsequent regulatory updates have expanded the scope of this mandate. Specifically, S.R.O. 69(I)/2025, issued on January 29, 2025, amended the Sales Tax Rules, 2006, to extend the electronic invoicing requirements to all sales tax-registered persons, regardless of their sector. This broader mandate was further reinforced by S.R.O. 709(I)/2025, which set compliance deadlines for corporate and non-corporate entities.
In summary, while S.R.O. 709(I)/2025 initially applied to specific FMCG-related businesses, subsequent amendments have broadened the electronic invoicing obligations to encompass all sales tax-registered entities in Pakistan.
Get Digital or Get Left Behind: What Businesses Should
Given the rapid evolution of the digital tax environment and the imminent deadlines, affected businesses should act without delay. The following steps are essential:
- Determine Entity Classification
Confirm whether your business is registered as corporate or non-corporate to identify your compliance deadline: 1 July 2025 or 1 August 2025 respectively. - Assess Current Systems
Evaluate your existing invoicing software and point-of-sale hardware. Are they capable of meeting the FBR’s requirements for real-time data transmission and e-invoice formatting? - Choose an Integration Partner
Connect with a licensed integrator or PRAL. If you do not already have a service provider, this step should be prioritised immediately. - Test and Train
Once integrated, conduct thorough testing of your system’s ability to generate and transmit electronic invoices accurately and securely. Ensure your staff is trained to handle exceptions, such as offline invoice generation during outages. - Stay Informed
Given the rapidly changing landscape, it's critical to remain updated on additional notifications, changes in the rules, or new integration guidelines. Subscribing to regulatory updates or consulting with a compliance advisor can be helpful.
Act Fast: The Clock Is Ticking
Businesses impacted by the mandatory e-invoicing rules in Pakistan must move swiftly. The stakes are high: non-compliance may result in penalties, tax adjustments, and reputational risks. The deadlines (1 July 2025 for corporate entities and 1 August 2025 for non-corporates) are rapidly approaching, and the integration process requires careful coordination.
If your business operates in the FMCG sector and you are a registered importer, distributor, manufacturer, or wholesaler, it’s essential that you become compliant before these dates.
We strongly recommend that you:
- Engage with a trusted e-invoicing partner such as the eezi team, who are well-versed in the technical and regulatory nuances of global e-invoicing mandates.
- Visit the eezi website and explore our blog content to learn more about how other jurisdictions are implementing electronic invoicing and what lessons can be applied to the Pakistan e-invoicing framework.
With the FBR moving decisively towards real-time digital invoicing, the message is clear: now is the time to integrate. Don’t wait until the final hour - get connected, get compliant, and embrace digital transformation.
