Regulatory updates - Pakistan

On January 29, 2025, the Federal Board of Revenue (FBR) of Pakistan issued Notification S.R.O. 69 (I) 2025, which will significantly change the country’s sales tax invoicing system.

The amendments to the Sales Tax Rules, 2006, require all registered persons to integrate their sales tax invoicing systems with the FBR’s computerized system from February 3, 2025.

Under the new provisions, businesses must use approved hardware and software systems that generate digital invoices, including QR codes, and transmit transaction data to the FBR in real time. Registered persons are also required to ensure proper data storage and maintain logs for auditing purposes. Failure to comply with these requirements will result in penalties.

Scope of e-invoicing

The provisions apply to all registered persons for electronic integration of hardware/software for generating and transmitting electronic invoices. E-invoicing is also required for exempt goods, ensuring all transactions are electronically recorded for transparency.

Registered persons who are already integrated with the FBR’s system are exempt from re-registration.

Obligations of integrated persons

Registered persons must integrate their sales tax invoicing systems with the FBR’s computerized system.

Sales invoicing through integrated outlets or POS (Point of Sale) must generate invoices, create digital signatures, transmit data to the FBR’s system, and issue a unique invoice number.

Integration requirements also include generating QR codes, storing data securely, and maintaining logs for auditing purposes.

Licensing of integrators

No person can integrate sales tax systems unless licensed by the FBR. 

PRAL (Pakistan Revenue Automation (Pvt) Limited) is designated as a licensed integrator responsible for providing integration services.

Timelines and extensions

Registered persons must integrate their systems from February 3, 2025.

The Commissioner Inland Revenue can extend the deadline by up to 60 days (in 15-day intervals).

Data storage

All software and hardware systems must be capable of securely transmitting and storing data for at least 6 years for audit purposes.

Additional provisions

The provisions apply to both online and offline sales. In case of internet or system failure, offline invoices will be allowed but must be uploaded to the system within 24 hours of restoration.

The system may require integrating debit/credit card payment facilities and maintaining CCTV records at points of sale.

As previously reported by Pagero, Pakistan is gradually introducing mandatory e-invoicing in the clearance CTC model to modernize transaction controls.

On 18 April 2024, the Federal Board of Revenue (FBR) of Pakistan unveiled the updated version 1.3. of the technical specification for data sharing through API via FBR. This document aims to walk Supply Chain Operators through Digital Invoice Data sharing methods with FBR.

The technical specification document covers the PoS registration process, integration steps with FBR, invoice model details, web API functionality, sample codes, posting model in Postman, and annexures such as sale type codes, SRO/Schedule codes, UOM codes, and HS codes.

Obligation timelines

Starting from 1 February 2024, e-invoices must be submitted by tax-registered persons dealing with fast-moving consumer goods (FMCG).

The outline of the mandate

Registered persons notified by FBR will issue electronic sales tax invoices in JSON format for every taxable supply in real time. These persons must integrate their PoS, ERP, or any other invoicing system with FBR through a licensed integrator. Until the FBR approves the list of licensed integrators, registered persons dealing with FMCG have to integrate their e-invoicing system with the FBR system without licensed integrators.

Pagero closely follows the developments and will inform our customers once further guidance is announced.

FBR has embarked on a pioneering tax reform initiative by introducing the SWAPS. This digital transformation aims to boost tax transparency and combat evasion.

Through the Statutory Regulatory Order (SRO) 419(I)/2024, the FBR has amended the Income Tax Rules/2002, paving the way for SWAPS implementation to modernize withholding tax processes, transitioning them to the digital sphere.

Designated SWAPS Agents are required to align with regulatory standards, refine their profiles within the Integrated Risk Information System (IRIS) and adopt approved electronic devices for withholding tax transactions.

SWAPS mandates all specified transactions to occur through its platform, ensuring every digital invoicing aligns with critical withholder information. Failure to comply may lead to penalties outlined in the Income Tax Ordinance/2001.