On April 22, 2025, the Pakistan Federal Revenue Board (FBR) issued the Notification S.R.O. 709 (I) /2025, making electronic invoicing mandatory for a wide range of FMCG companies. The key dates are:
• Legal entities (corporate): they must comply before May 1, 2025.
• Non-legal (non-corporate) persons: they must comply before June 1, 2025.
These deadlines seek to ensure a smooth transition, but companies must act quickly to avoid sanctions and enforcement actions.
How does e-Invoicing work in Pakistan?
All obligated companies must digitally generate and transmit sales tax invoices through software that integrates with the FBR's central system, either through authorized integrators or through Pakistan Revenue Automation Limited (PRAL).
Key requirements for billing in this country:
• Model: centralized. The invoice must be generated and transmitted in digital format through billing software that is integrated with the FBR system.
• Real-time generation and transmission: invoice data must be sent immediately and in encrypted form.
• Invoice format: JSON. If a software vendor (or PDP) generates XML documents in its internal system, before sending the invoice to the FBR, said system must convert the information to the JSON format, which is the only officially accepted format for transmission and integration with the government platform.
• Archiving: 6 years.
• Offline scenarios: In case of connection failures, bills must be marked as “offline” and charged within a maximum period of 24 hours after restoring connectivity.
• The invoice must include these fields:
- Date and time of issue.
- Full details of the seller and buyer (name, address, Sales Tax Registration Number - STRN).
- Detail of the products or services (description, quantity, unit of measure, unit value and total).
- Product Codes (H.S. Codes. When applicable, especially for importers and exporters).
- Fees and applicable taxes.
- Discounts, if any.
- Reference to SRO notifications if applicable (Statutory Regulatory Order, which are notifications, exemptions, or other specific requirements issued by the FBR)
- Payment method.
• Digital Signature, QR Code and Universal Unique Identifier (UUID): they are mandatory but they break the norm, that is, it is not the traditional process that we know. In the case of Pakistan, both the electronic signature and the QR code are generated by the competent authorities, in this case the FBR.
How does eInvoicing in Pakistan works?
1) When the company issues an electronic invoice, it sends it in JSON format through the official API to the tax authorities, the FBR.
2) The FBR validates the content and, if everything is correct, returns the invoice validated and digitally signed by the FBR itself.
Resuming, the FBR is the one who generates the QR code and includes it together with the digital signature and the UUID in the official response. The electronic signature in Pakistan is the guarantee of validation and authenticity issued by the FBR.
Who is required to e-invoice in Pakistan?
The obligation covers the following entities related to FMCG:
• Importers
• Manufacturers
• Wholesalers, distributors and dealers
• Wholesalers-retailers who supply retailers in large volumes
The regulation also specifies that each point of sale (POS) must be registered and show its integration status with the FBR with the phrase “integrated into the FBR”.
Global e-invoicing with Brait
The clock is ticking for the mandatory electronic invoicing in several countries around the world. Failure to comply could mean financial penalties and operational difficulties, while timely integration sets your company up for success in an increasingly digital environment.
At Brait we have a extensive experience in global electronic invoicing. More specifically, we work to support several international customers, adapting SAP systems to the new regulations through our Invictia connector. Choosing Brait means being able to count on a professional and expert supplier that gives you the peace of mind to ensure your company's operations, turnover, compliance in different countries, as well as being aware of future regulatory updates. Contact us today!
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