FBR E-Invoicing / Digital Invoicing Integration

Muhammad Shahzad

8/4/20252 min read

The FBR is moving sales tax invoicing from paper/stand-alone systems into a real-time, structured e-invoicing system so invoice data is generated/transmitted/stored electronically and shared with FBR’s systems (directly or through licensed integrators/PRAL). The goals are improved VAT compliance, fraud reduction, easier audits, and automated reporting.

Rules / SROs

• S.R.O. 1525(1)/2023 — earlier notification that introduced requirements for issuance of electronic invoices and defines “integrated supplier” concept; foundational text for e-invoicing.

• S.R.O. 69(I)/2025 (29 Jan 2025) — FBR replaced Chapter XIV of the Sales Tax Rules; includes provisions on licensing, integrators, PRAL role, and technical/testing frameworks. (See official SRO PDF on FBR site.)

• S.R.O. 709(I)/2025 (22 Apr 2025) — sets integration deadlines and expanded scope (initially broadened to require integration for most registered persons). Summarized and discussed in professional briefs.

• S.R.O. 1413(I)/2025 (1 Aug 2025) — latest directive / notification setting or reaffirming final deadlines and clarifications (see industry reporting; check official FBR link for text). (Note: date sensitive — confirm official PDF for exact wording if you need certitude.)

Who must integrate

• The scope has been progressively widened. Under the latest SROs, all registered persons under the Sales Tax Act are expected to integrate with the FBR e-invoicing system through:

o a notified/licensed integrator (private third-party integration service) or

o PRAL (Pakistan Revenue Automation Ltd.), which may provide a free downloadable invoicing/POS application for smaller taxpayers.

• Earlier waves prioritized large FMCG/manufacturers/distributors and high turnover taxpayers; SROs 709 and 69 expanded or clarified scope toward broader coverage.

Deadlines (important — have changed; confirm current one before action)

Different SROs introduced/altered deadlines. The more important dates referenced in industry notices are:

• SRO 709(I)/2025 (22 Apr 2025): originally required

o Corporate registered persons → 1 May 2025

o Non-corporate registered persons → 1 June 2025.

• Extensions / revisions: FBR issued one-month extensions in some communications (pushing corporate → 1 June 2025 and non-corporate → 1 July 2025 in some briefings), and later updates (including SRO 1413(I)/2025) adjusted/confirmed final dates and implementation waves.

PRAL & licensed integrators

• PRAL (Pakistan Revenue Automation Ltd.) is explicitly referenced in SROs as an alternative integration path and may offer a free downloadable e-invoicing/POS application for taxpayers who cannot afford or do not need a commercial integrator. The SRO text mentions PRAL’s role in providing software and testing support.

• EY Ford Rhodes

• Haball Pvt. Ltd.

• Webdnaworks Pvt. Ltd.

Penalties & enforcement

• Non-compliance can lead to administrative action under Sales Tax rules — including penalties, T-1 return processing issues, and potentially audit attention. Several professional advisories note FBR intends to enforce via returns and system checks.