The Federal Board of Revenue (FBR) has undertaken a significant journey to digitize tax compliance, particularly through the progressive rollout of digital invoicing and e-invoicing systems. This transformation has been guided primarily by a series of Statutory Regulatory Orders (SROs), each building upon the previous framework to strengthen integration, compliance, and transparency in business transactions.
Latest Mandate Expands Scope: SRO 709(I)/2025
The most recent step in this journey came through SRO 709(I)/2025, issued on April 22, 2025. Through this directive, the FBR mandated that all sales tax-registered businesses across all sectors must integrate their invoicing systems with the FBR’s digital platform by June 1, 2025. Unlike previous initiatives limited to Tier-1 retailers, SRO 709(I)/2025 expanded the scope universally. It required the real-time transmission of all sales tax invoices to the FBR using approved hardware and software, aligning closely with the rules already introduced in SRO 69(I)/2025 regarding e-invoicing.
Building the E-Invoicing Framework: SRO 69(I)/2025
Earlier this year, SRO 69(I)/2025 was issued on January 29, 2025, and initially set a compliance deadline of February 3, 2025, although a 60-day extension was allowed. This critical SRO amended Chapter XIV-B of the Sales Tax Rules, 2006, making it compulsory for all registered businesses to issue electronic sales tax invoices containing unique FBR-assigned invoice numbers and QR codes. It reinforced the need for real-time data transmission through licensed integrators and imposed a mandatory six-year record-keeping requirement. Importantly, businesses already compliant under SRO 28(I)/2024 were deemed to have fulfilled these requirements, demonstrating FBR’s effort to streamline overlapping obligations.
Laying the Groundwork: SRO 28(I)/2024 and Early Initiatives
Looking back further, SRO 28(I)/2024 had been a key turning point. Issued on January 10, 2024, it focused on the fast-moving consumer goods (FMCG) sector, compelling importers, manufacturers, wholesalers, distributors, and wholesaler-cum-retailers to issue electronic invoices in JSON format. This SRO laid the groundwork for broader digital invoicing practices, requiring businesses to integrate their point-of-sale (POS) or enterprise resource planning (ERP) systems with the FBR through licensed integrators. Initially sector-specific, the framework later evolved through SRO 69(I)/2025 to encompass all industries.
Refining Retail Compliance: SRO 614(I)/2024 and SRO 1525(I)/2023
Another vital building block was SRO 614(I)/2024, issued on April 26, 2024. Although it did not specify a compliance deadline, it amended the earlier SRO 230(I)/2022 and updated technical standards for POS system integration among Tier-1 retailers. The FBR, through this SRO, ensured that sales data—including returns—was transmitted electronically in real-time, refining the connectivity protocols introduced earlier and addressing practical issues faced under SRO 1525(I)/2023.
Speaking of SRO 1525(I)/2023, this directive was pivotal in strengthening retail sector compliance. Issued on October 12, 2023, it mandated Tier-1 retailers to integrate their POS systems with the FBR’s live invoicing platform. Retailers were instructed to generate electronic invoices carrying FBR-assigned identifiers for all transactions, aiming to minimize tax evasion through strict digital oversight. The SRO updated previous technical frameworks first introduced under SRO 1006(I)/2021, further enhancing the FBR’s digital reach.
Procedural Guidance: Sales Tax General Order 01 of 2024
Complementary to these regulatory instruments was the issuance of Sales Tax General Order 01 of 2024, which provided detailed procedural guidance. This order supported the implementation of technical standards set by SRO 614(I)/2024, ensuring Tier-1 retailers adhered to real-time electronic invoicing without introducing additional amendments to previous SROs.
In conclusion, the FBR’s journey toward complete digital invoicing integration reflects a deliberate and phased strategy. Through successive SROs, the FBR has built a robust digital infrastructure aimed at promoting transparency, increasing tax compliance, and modernizing Pakistan’s taxation system to meet global standards. With each new SRO, the FBR moves closer to realizing a fully digitized, transparent, and efficient tax collection environment.
