Pakistan’s Federal Board of Revenue (FBR) has introduced SRO 69(I)/2025, bringing significant reforms to the Sales Tax Rules, 2006 by implementing mandatory e-Invoicing, real-time compliance, and a structured licensing framework for e-Invoicing service providers.
This notification establishes:
- Scope of the New e-Invoicing Regulations – Key requirements, mandatory digital invoicing, and compliance obligations.
- Integration Methods for e-Invoicing – Businesses must either integrate through licensed service providers or opt for direct integration if they are an online marketplace.
- Mandatory CCTV Surveillance for Compliance – Businesses must install CCTV cameras at sales points and retain footage for at least one month for compliance verification.
- PRAL as the Government-Backed e-Invoicing Integrator – The Pakistan Revenue Automation Limited (PRAL) has been designated as FBR’s official integrator and provides free-of-cost integration.
- Licensing Process for e-Invoicing Service Providers – A strict approval framework for private service providers, with more than 30 companies currently awaiting FBR’s approval.
- Technical Requirements for e-Invoicing Compliance – Businesses must ensure invoices include QR codes, digital signatures, and automatic tax return integration.
- Enforcement & Monitoring by FBR – The Inland Revenue Enforcement Network will conduct audits, inspections, and compliance checks to ensure businesses follow the new regulations.
- Conclusion: A New Era for Digital Tax Compliance in Pakistan – A look at what businesses must do and the future impact of this digital transformation.
1.1. Who Must Comply?
- The new e-Invoicing system applies to all businesses notified by FBR through an official Gazette notification.
- Businesses must register, install, and integrate their invoicing systems with FBR’s network.
1.2. Key Requirements for Businesses
- Issue real-time, verifiable electronic invoices containing:
- Unique FBR Invoice Number
- Digital Signature
- QR Code
- Maintain electronic records for six years.
- Transmit invoice data to FBR’s system in real-time.
- Implement CCTV monitoring for sales transactions.
1.3. Elimination of Manual Invoices
- No business can issue paper-based invoices for taxable supplies.
- Failure to comply will result in penalties under Section 33 of the Sales Tax Act, 1990.
2. Integration Methods for e-Invoicing
FBR has provided two methods for businesses to integrate into the e-Invoicing system.
2.1. Integration via Licensed Service Providers
- This method applies to most businesses that need to integrate with FBR’s network.
- Businesses must use a licensed e-Invoicing service provider for integration.
- The licensed integrator ensures compliance, system security, and real-time data transmission.
2.2. Direct Integration for Online Sales Platforms
- Online sales platforms, e-commerce marketplaces, and digital retailers can integrate directly with FBR.
- They must register their website, software, and mobile application with FBR.
- All invoices must be generated and transmitted automatically to FBR’s network.
2.3. Can Businesses Integrate Directly Without a Licensed Service Provider?
- No, Online marketplaces and e-commerce platforms can integrate under Rule 150R(12) but the Notification never mentioned a direct integration of the website, software or mobile app.
- Rule 150XE(1) states that businesses must integrate through a licensed service provider.
- Online marketplaces and e-commerce platforms can integrate directly under Rule 150R(12).
3. Mandatory CCTV Surveillance for Compliance
3.1. Key Requirements
- All notified businesses must install CCTV cameras at their point of sale (POS).
- Footage must be stored for at least one month.
- FBR officials can request CCTV footage at any time for compliance verification.
3.2. Purpose of CCTV Monitoring
- Ensures accurate tax reporting and prevents unreported cash transactions.
- Strengthens Pakistan’s shift toward a fully monitored tax ecosystem.
4. PRAL as the Government-Backed e-Invoicing Integrator
4.1. PRAL’s Role
- Acts as the official government e-Invoicing integrator.
- Provides free-of-cost integration services.
- Offers a downloadable invoicing software on FBR’s website.
- Ensures secure, real-time data transmission.
4.2. Alternative to PRAL
- Private companies can apply for a license to become e-Invoicing integrators.
- Businesses can choose between PRAL and a licensed private provider.
5. Licensing Process for e-Invoicing Service Providers
5.1. Who Needs a License?
- Any company that wants to provide e-Invoicing integration services must obtain a license from FBR.
- PRAL is exempt from this requirement.
5.2. Licensing Criteria
Companies must meet the following criteria to qualify for a license:
- Proven expertise in e-Invoicing, ERP, and payment system integration.
- Minimum paid-up capital of Rs. 10 million.
- Registered with Pakistan Software Houses Association or Institute of Chartered Accountants of Pakistan.
- Audited financial statements for the last three years.
- A team of technical experts dedicated to system integration and security.
- Undertaking that the company has never been blacklisted.
5.3. Approval Process
- Applications are submitted to FBR’s Licensing Committee.
- The committee evaluates financial standing, technical capacity, and compliance history.
- If approved, the license is valid for five years.
- If rejected, companies can appeal to FBR for reconsideration.
5.4. Current Status of Licensing Approvals
- More than 30 companies are waiting for approval to become licensed service providers.
- FBR’s slow approval process is delaying the expansion of the service provider market.
6. Technical Requirements for e-Invoicing Compliance
6.1. Electronic Invoice Format
- Every invoice must contain:
- Unique FBR Invoice Number
- QR Code (7x7mm size)
- Seller and Buyer Details
- Item Descriptions, Tax Rate, and Total Value
- Pre-Filled Tax Return Integration (Annexure-C)
6.2. Compliance Rules for Businesses
- Internet or System Failures: If an invoice cannot be issued due to a technical failure, it must be uploaded within 24 hours after system restoration.
- Signboard Requirement: Every notified business must display a signboard stating: “Integrated with FBR” along with its registration number.
- Online Sales Platforms: Must ensure invoices are auto-generated and stored electronically.
7. Enforcement & Monitoring by FBR
7.1. Compliance Monitoring by Inland Revenue Enforcement Network
- Random physical inspections of businesses.
- Surprise audits using CCTV footage and electronic logs.
- Public verification tools to check invoice authenticity.
7.2. Penalties for Non-Compliance
- Businesses failing to integrate will face penalties under Section 33 of the Sales Tax Act, 1990.
- Issuing paper invoices or bypassing the system will result in fines and enforcement action.
8. Conclusion: A New Era for Digital Tax Compliance in Pakistan
Pakistan’s e-Invoicing notification introduces strict regulations, real-time monitoring, and structured compliance mechanisms to modernize the country’s tax system.
8.1. What Businesses Must Do Now
- Choose an integration method – licensed service provider or direct integration for online platforms.
- Implement CCTV monitoring at all sales points.
- Ensure all invoices comply with FBR’s digital requirements.
- Adopt licensed invoicing software to ensure compliance.
8.2. The Future of Tax Compliance in Pakistan
This notification marks a critical transformation in Pakistan’s tax system. The speed of implementation and business adaptation will determine the success of this new e-Invoicing framework.
