Context and Background
Pakistan’s Federal Board of Revenue (FBR) has issued S.R.O. 1413 (I)/2025, replacing the earlier April 2025 notification. This sets a clear and phased schedule for the rollout of mandatory electronic invoicing. The reform builds on the earlier requirement (from February 2024) where importers, manufacturers, and wholesalers of fast-moving consumer goods (FMCG) were first brought into scope. Now, the net expands to cover almost all registered taxpayers, using software digitally integrated with the FBR through licensed integrators or PRAL.
Why this Shift?
The objective is straightforward: tighten compliance, ensure real-time sales tax reporting, and close VAT leakage by linking business invoicing systems directly to the FBR.
The Phased Rollout ‒ Who Comes in, and When
The notification provides a structured calendar with mandatory testing dates, issuance start dates, and integration deadlines :
- Public companies, large companies (> PKR 1 billion turnover), and all importers
- Testing deadline: 10 August 2025
- Go-live for issuance: 1 September 2025
- Companies with turnover > PKR 100 million but ≤ PKR 1 billion
- Testing deadline: 10 September 2025
- Go-live: 1 October 2025
- Companies with turnover ≤ PKR 100 million
- Testing deadline: 10 October 2025
- Go-live: 1 November 2025
- Individuals and Associations of Persons (AOPs) with turnover > PKR 100 million
- Testing deadline: 10 September 2025
- Go-live: 1 October 2025
- All remaining registered persons
- Testing deadline: 10 November 2025
- Go-live: 1 December 2025
Technical and Legal Obligations
- Businesses must complete integration and registration with FBR systems through either PRAL or a licensed integrator before their respective go-live date.
- E-invoices must be issued via digitally linked invoicing software, ensuring direct reporting to FBR.
- Non-compliance after the respective deadline risks administrative action, including penalties.
Testing Phase Importance
Each category has a two-step process: registration and testing → issuance. This ensures businesses validate their system setup before the mandatory date.
Broader Compliance Implications
- Audit trail: E-invoices create a verifiable digital footprint, reducing the possibility of under-reporting.
- Cash economy reduction: Linking invoices digitally with FBR restricts off-book sales.
- Administrative impact: Businesses must align ERP/accounting systems with FBR specifications ‒ failure to prepare early may result in operational bottlenecks.
Strategic Steps for Businesses
- Assess scope: Determine if you fall under the public company, importer, or turnover-based categories.
- Upgrade systems: Integrate ERP/accounting solutions with FBR’s clearance system.
- Test early: Use the testing window before your go-live date to iron out errors.
- Train staff: Ensure finance and operations teams understand new workflows and validation requirements.
Key Takeaway
Pakistan’s e-Invoicing reform is no longer on the horizon ‒ it’s on the calendar. By September 2025, public companies, large businesses, and importers must comply. By December 2025, nearly all registered taxpayers will be onboard. This transition demands early preparation, system readiness, and active testing to avoid disruption once the deadlines hit.
