The Federal Board of Revenue (FBR) of Pakistan has taken a significant step to advance digital compliance and streamline tax administration by mandating the integration of electronic invoicing systems. As per S.R.O.709(I)/2025, issued on April 22, 2025, corporate and non-corporate registered entities must electronically link their systems with the FBR’s computerized platform through licensed integrators or PRAL.
1. Key Deadlines for Integration
1.1 Corporate Registered Persons
- Deadline: May 1, 2025
- Requirement: Full electronic integration of hardware and software with the FBR’s customs computerized system.
1.2 Non-Corporate Registered Persons
- Deadline: June 1, 2025
- Requirement: Same integration requirement as corporate entities, with a one-month extension.
2. Scope of the e-Invoicing Mandate
The integration mandate applies specifically to businesses dealing in fast-moving consumer goods (FMCG). The following categories are explicitly covered:
2.1 Covered Business Categories
- Importers of FMCG
- Manufacturers of FMCG
- Wholesalers, dealers, and distributors of FMCG
- Wholesaler-cum-retailers engaged in bulk import and wholesale supply of FMCG to retailers
These entities are now obligated to generate and transmit sales tax invoices electronically as per Rule 150Q under Chapter XIV of the Sales Tax Rules, 2006, reinforced through Notification No. 1525(I)/2023.
3. Integration Process
3.1 Authorized Integrators
Entities must integrate their invoicing systems via:
- Licensed Integrators (There are 3 licensed integrators as of April) or
- Pakistan Revenue Automation Limited (PRAL)
The e-invoices must be generated and transmitted in real-time and reflect transactions from the specified effective dates.
4. Regulatory Reference and Legal Basis
The directive is issued under:
- Section 50 of the Sales Tax Act, 1990
- Sub-rule (2) of Rule 150Q of the Sales Tax Rules, 2006
It formalizes the FBR’s continued push towards transparent, digital-first tax practices.
5. Background and Previous Obligations
5.1 February 1, 2024 Compliance Requirement
Prior to this latest S.R.O., the FBR had already enforced a similar e-invoicing requirement starting February 1, 2024, for:
- Importers and manufacturers of FMCG
- All distributors, wholesalers, and dealers of FMCG
- Wholesaler-cum-retailers involved in bulk imports and supply
These entities were instructed to transmit sales tax invoices electronically in compliance with previously issued regulatory frameworks.
6. Next Steps for Businesses
Businesses falling within the scope of this directive should:
- Confirm their registration type (corporate or non-corporate).
- Evaluate existing invoicing systems for compatibility with FBR’s requirements.
- Engage with PRAL or licensed integrators to commence integration ahead of the deadlines.
- Test their systems to ensure seamless generation and transmission of e-invoices.
The issuance of S.R.O.709(I)/2025 on April 22, 2025, marks another strategic move by the FBR to embed digitization into Pakistan’s tax framework. With staggered deadlines for corporate and non-corporate entities, the objective is clear: enhance real-time reporting, minimize tax evasion, and build a data-driven tax administration environment.
FMCG businesses should act swiftly to meet the integration deadlines and ensure uninterrupted compliance with national tax laws.
