Pakistan Extends E-Invoicing Implementation Schedule
On September 24, 2025, Pakistan’s Federal Board of Revenue (FBR) issued Notification S.R.O. 1852(I)/2025, revising once again the rollout timeline for the country’s mandatory electronic invoicing system. This new notification replaces the earlier S.R.O. 1413(I)/2025 from August 2025 and provides businesses with approximately two additional months to prepare for compliance.
Revised Implementation Deadlines
The updated regulation maintains the category-based implementation model introduced earlier while extending the deadlines across all taxpayer groups:
Businesses with annual turnover above PKR 1 billion (~EUR 3 million), all public companies, and importers
- Registration: October 15, 2025
- Testing: October 25, 2025
- Issuance: November 1, 2025
Companies with turnover between PKR 100 million and 1 billion (~EUR 300,000–3 million)
- Registration: October 25, 2025
- Testing: October 31, 2025
- Issuance: November 15, 2025
Individuals and associations with turnover exceeding PKR 100 million (~EUR 300,000)
- Registration: October 10, 2025
- Testing: October 25, 2025
- Issuance: November 1, 2025
Companies with turnover below PKR 100 million (~EUR 300,000)
- Registration: November 15, 2025
- Testing: November 25, 2025
- Issuance: December 1, 2025
All remaining registered persons
- Registration: December 10, 2025
- Testing: December 25, 2025
- Issuance: December 31, 2025
Integration and Technical Requirements
The core integration obligations remain unchanged. All sales tax-registered persons must connect their invoicing and accounting systems to the FBR’s e-invoicing system, either through a licensed system integrator or Pakistan Revenue Automation Limited (PRAL).
Penalties for non-compliance remain in effect under the Sales Tax Act, 1990.
Implications for Taxpayers
The e-invoicing mandate, introduced under the Finance Bill 2024, is part of Pakistan’s broader digital tax modernization initiative, aimed at improving transparency, strengthening compliance, and combating tax evasion.
The revised schedule provides businesses with additional time to align internal systems and conduct more comprehensive testing and training before the system becomes fully operational. Companies that have already begun their integration efforts should continue according to the revised timeline to ensure uninterrupted compliance once mandatory issuance takes effect.
There’s more you should know about global e-invoicing changes – learn more about the new and upcoming regulations.
