Regulatory updates - Pakistan

On February 18, 2026, the Federal Board of Revenue (FBR) of Pakistan issued a draft notification proposing to replace Chapter VIIA of the Income Tax Rules, 2002 with a new framework requiring specified sectors to integrate e-invoicing/POS systems with FBR for real-time electronic invoices/bills, including QR codes, digital signatures, record retention, audit access, and a licensing regime for integrators.

Scope

Covered categories include, but are not limited to:

• restaurants;
• hotels/hostels/marriage halls/clubs;
• inter-city road travel;
• courier/cargo; personal care services;
• medical providers (with fee threshold exclusion);
• diagnostics/hospitals;
• gyms/clubs;
• photographers/event managers (with per-event fee threshold exclusion);
• accountants;
• retailers (with chain/mall/electricity bill/size-based tests);
• foreign exchange dealers; and
• private education institutions (with a monthly fee-per-child threshold exclusion).

Requirements for “integrated enterprises”

Notified taxpayers (“integrated enterprises”) must register, install, and integrate e-invoicing hardware/software with FBR’s computerised system, provide outlet/POS details via FBR’s online system, and ensure no supplies are made except through integrated outlets/POS/e-invoice or bill issuing machines.

Technical requirements

POS/e-invoicing systems must:

• support secure transmission of invoice/bill data to FBR and receipt of a unique FBR invoice/bill number,
• generate and print a QR code based on that number,
• create and record digital signatures,
• maintain logs for adjustments/cancellations and system events, and
• perform day/week/month closing routines.

Offline mode and business continuity

Invoices/bills issued during system failure (including internet or power disruption) must be clearly marked as offline mode and uploaded to FBR within 24 hours of restoration.

Licensing of integrators

The draft establishes a licensing framework for entities that integrate taxpayers’ software with FBR, including application documentation requirements, license validity/renewal, technical support duties, fee caps via general order, and cancellation procedures.

PRAL is designated to act as a licensed integrator for these purposes and may provide free-of-cost integration and downloadable software when required.

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.