Live e-invoice reporting to Federal Board of Revenue 15 October launch
The Pakistani Federal Board of Revenue (FBR) has yet again rescheduled the launch of structured e-invoicing launch. Registrations for the first wave are now largely complete, but the start date is put back one month, to 15 October. The new launch plan is:
- 15 October 2025: large companies – annual sales about 1 billion rupees (approx €10 million) – which should be registered for testing by 10 August. This will include B2G invoice issuers;
- 1 November: mid companies and unincorporated persons – annual sales between 1 billion and 100 million rupees;
- 31 December: small companies below 100 million rupees
This follows the 2024 Finance Bill and F. No. 1(141) ST-L&P/2025/55105-R introduced to the National Assembly confirming the introduction of mandatory e-invoicing. The process of registering with FBR started in February this year.
Since April 2024, importers and FMCG taxpayers have been subject to e-invoicing reporting.
The FBR is confirming with all affected taxpayers their obligations. This would cover importers, manufacturers and wholesalers/dealers/distributors of fast-moving consumer goods to integrate their electronic invoicing system with the FBR’s digital invoicing system.
The requirement is for an invoice JSON file submission, with the return of a unique code to be embedded with the e-invoice before submission to the customer. Integration must be via approved software, or a certified integrator for other systems, including in-house developed systems.
In case of online sale including online market place, the integrated person shall register such website, software and mobile application with the Board’s Computerised System to record the auto-electronic invoices as specified by the Board through a Sales Tax General Order.
E-invoicing functionality requirements
The requirements for the functionality include:
- generate, receive, record, analyze and store invoice data;
- issue sales tax invoices in the prescribed format, create the digital signature and record the digital signature on the sales tax invoice;
- transmit the invoice data to the Board’s Computerised System through secure means and receive the unique FBR invoice number;
- encrypt and preserve the reported sales tax invoice data in an irrevocable and secure manner;
- generate the QR Code on the base of unique FBR invoice number and print the QR Code on receipt;
- must perform closing on close of the day, week and month; and
- every adjustment, modification or cancellation must be recorded duly maintaining logs for each activity; and system events need to be recorded.
B2C fiscal registers
Taxpayers, known as ‘integrated suppliers’ must shortly instal VAT fiscal registers for B2C invoicing. This includes: Manufacturers, importers, wholesalers and distributors of fast-moving consumer goods. FBR will notify affected suppliers.
Fiscal registers will be provided by certified distributors. These registers will provide automated daily direct reporting to the FBR. But the integrated supplier shall allow physical and online remote access to the records, systems, logs and documents maintained in electronic form.
