FBR digital invoicing: cost, penalties and deadlines

FBR charges no fee to connect to its digital invoicing system, so the cost of compliance is entirely software, integrator work and hardware. The penalties sit in section 33 of the Sales Tax Act 1990, the obligation to integrate comes from section 23 and Chapter XIV of the Sales Tax Rules 2006, and the dates come from a separate notification that has been replaced twice, which is why most published deadline tables are wrong.

What it costs

Start with the good news. FBR does not charge a fee to connect to its system. The integration itself is free. Your real costs sit in three places, and they vary a lot by business size.

• Software. Unless you build your own connection, you pay for invoicing software that submits to FBR. For a small business this is a modest monthly or yearly fee. For a large one with high volumes it is still small next to the staff time it saves.
• Setup and integration. If you use a licensed integrator, their fees are capped by FBR, so you are not exposed to open-ended charges. If you use ready software, setup is usually included.
• Hardware. Most businesses already have what they need, a computer or a POS. Some retail setups add a receipt printer or a barcode scanner, but this is optional.

If you build the integration in house instead, you trade the software fee for developer time. That can be worth it for a company with its own tech team, and rarely worth it for anyone else.

What the penalties look like

This is the question most often answered badly online, with figures ranging from fifty thousand rupees to three million depending on which page you land on. The figures are not a matter of opinion. They are set out in section 33 of the Sales Tax Act 1990, in the table of offences, and you can read them yourself in FBR's own consolidated text of the Act as amended up to 30 June 2026.

The entry that covers digital invoicing is serial number 25A. It applies to a person required to integrate who fails to register, or who registers and then fails to integrate as the law and rules require, and since the Finance Act 2025 it also covers failing to issue electronic invoices after integration. The penalty is a ladder:

• PKR 500,000 for the first default.
• PKR 1,000,000 for a second default, fifteen days after the order for the first.
• PKR 2,000,000 for a third default, fifteen days after the order for the second.
• PKR 3,000,000 for a fourth default, fifteen days after the order for the third.

Separately from the money, and expressly notwithstanding it, the business premises are liable to be sealed by an officer of Inland Revenue in the prescribed manner. There is one way back: the Act provides that if a retailer integrates with FBR's computerized system before the penalty for the second default is imposed, the Commissioner shall waive the penalty for the first default.

A second entry, serial number 25, was substituted by the Finance Act 2026 and covers persons required to integrate for the monitoring, tracking, reporting or recording of sales under section 40C. It runs on a different scale: a penalty of up to PKR 1,000,000, and if the offence continues a month after the first penalty is imposed, a second penalty of up to PKR 5,000,000, with premises sealable with or without a penalty having been imposed.

How the deadlines work, and why yours has probably passed

The obligation to integrate comes from section 23 of the Sales Tax Act 1990 and Chapter XIV of the Sales Tax Rules 2006. The dates come from a separate notification, and that notification has been replaced twice. A lot of content still in circulation, including earlier versions of this page, describes the first version.

• SRO 709(I)/2025, dated 22 April 2025, set the original schedule. It is no longer in force.
• SRO 1413(I)/2025, dated 1 August 2025, was issued expressly in supersession of SRO 709(I)/2025. It threw out the flat corporate and non corporate split and replaced it with seven categories banded by turnover. Read the gazette notification.
• SRO 1852(I)/2025, dated 24 September 2025, was issued in supersession of SRO 1413(I)/2025. It kept the same seven categories and pushed the dates back. This is the schedule that is operative today. Read the gazette notification.

Under SRO 1852(I)/2025 each category has three dates: one to complete registration, one to complete testing, and one to start issuing electronic invoices. Turnover is whatever you declared in your sales tax returns for the last twelve months.

• Public companies, importers, and companies other than public companies with turnover above PKR 1 billion. Register by 15 October 2025, test by 25 October, issue electronic invoices from 1 November 2025.
• Individuals and associations of persons with turnover above PKR 100 million. Register by 10 October 2025, test by 25 October, issue from 1 November 2025.
• Companies other than public companies with turnover above PKR 100 million but not above PKR 1 billion. Register by 25 October 2025, test by 31 October, issue from 15 November 2025.
• Companies other than public companies with turnover not above PKR 100 million. Register by 15 November 2025, test by 25 November, issue from 1 December 2025.
• Every other registered person. Register by 10 December 2025, test by 25 December, issue from 31 December 2025.

Read that last line again, because it is the one that matters most. The seventh category is a catch all, and its date has passed. If you are registered for sales tax in Pakistan and you are not issuing electronic invoices, you are not waiting for a phase. You are late, and the penalty ladder above is what you are exposed to.

One thing the rules give you back

A mistake on an issued electronic invoice is not permanent. Sales Tax General Order 01 of 2026, issued 30 March 2026, allows an integrated person to cancel, delete or edit a valid electronic invoice generated by a bonafide mistake, through FBR's computerized system, within seventy two hours of generating it. After that window it needs prior approval from the concerned Commissioner Inland Revenue. The same order confirms that a registered person may engage more than one licensed integrator, which had been a genuine source of confusion.

The cheapest way to be safe

For most businesses, the lowest-cost and lowest-stress path is ready software with a short setup, tested in validation mode, then switched to live. You avoid developer costs, you avoid the penalty ladder, and you spend an hour learning a screen instead of a month building an integration.

Last verified: 22 August 2026. Sources read directly for this page: SRO 709(I)/2025, SRO 1413(I)/2025 and SRO 1852(I)/2025 as published in FBR's SRO library; Sales Tax General Order 01 of 2026; and section 33 of the Sales Tax Act 1990 in FBR's consolidated text updated to 30 June 2026. General information, not tax or legal advice. A penalty is imposed by an order in your specific case, so confirm your own position with your consultant.