Pakistan E-Invoicing Update: FBR Sets May 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 May 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).
The deadlines are firm:
- Corporate registered persons must comply by 1 May 2025
- Non-corporate registered persons have until 1 June 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
According to S.R.O. 709(I)/2025, the e-invoicing obligation applies to a specific subset of FMCG businesses. The regulation explicitly lists the following categories:
- Importers of FMCG
- Manufacturers of FMCG
- Wholesalers, dealers, and distributors of FMCG
- Wholesaler-cum-retailers engaged in bulk import and supply to retailers
All notified persons must ensure that their electronic invoicing systems (hardware and software) are properly integrated. The FBR also mandates that each outlet or POS system must be registered, and integration status must be visibly displayed with the phrase "Integrated with FBR", including system registration details.
Failure to comply with this mandate carries significant consequences. Non-compliant businesses may face penalties under Section 33 of the Sales Tax Act, 1990, along with other enforcement actions. The FBR has also instructed its Inland Revenue enforcement network to patrol premises and verify integration and invoice transmission in real time.
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 May 2025 or 1 June 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 May 2025 for corporate entities and 1 June 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.
