The Federal Board of Revenue (FBR) of Pakistan has issued a new notification (S.R.O. 1852 (I)/2025) that further postpones the implementation schedule for the country’s mandatory e-invoicing system. This latest notification, dated 24 September 2025, replaces the previous schedule established in August (S.R.O. 1413(I)/2025) and grants businesses approximately two additional months to prepare for compliance.
Revised Implementation Timeline
The FBR has maintained the same category-based approach but extended all deadlines:
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Public companies, large businesses (turnover >1B PKR / >~€3M) & importers: Register by 15 Oct 2025, test by 25 Oct 2025, implement by 1 Nov 2025
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Medium companies (turnover 100M-1B PKR / ~€300K-3M): Register by 25 Oct 2025, test by 31 Oct 2025, implement by 15 Nov 2025
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Individuals & associations (turnover >100M PKR / >~€300K): Register by 10 Oct 2025, test by 25 Oct 2025, implement by 1 Nov 2025
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Small companies (turnover <100M PKR / <~€300K): Register by 15 Nov 2025, test by 25 Nov 2025, implement by 1 Dec 2025
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All remaining registered persons: Register by 10 Dec 2025, test by 25 Dec 2025, implement by 31 Dec 2025
Integration Requirements Unchanged
The core requirements remain consistent with previous notifications. All sales tax registered persons must integrate their hardware and software with the FBR’s computerized system through either a licensed integrator or Pakistan Revenue Automation Limited (PRAL).
What This Means for Taxpayers
This adjusted timeline provides businesses with additional preparation time to ensure smooth implementation of the e-invoicing requirements. Companies that have already begun integration with the previous timeline in mind should continue their implementation projects, using the extra time for more comprehensive testing and training.
For future updates on Pakistan and similar developments in other countries, follow our Regulatory Analysis page.
