FBR Penalties Loom for Non-Integrated e-Invoicing from January

The Federal Board of Revenue (FBR) is preparing to initiate penalty proceedings against sales tax-registered persons who have failed to integrate their systems for the issuance of electronic sales tax invoices, with enforcement commencing in January 2026 following the expiry of all category-specific integration deadlines.

Pursuant to SRO 1852(I)/2025, the FBR had granted phased extensions for mandatory integration. Public companies and importers were required to complete registration by October 15, 2025. Entities not classified by turnover thresholds were directed to register by December 10, 2025.

The regulatory framework mandates that all registered taxpayers integrate their hardware and software with the FBR’s computerized system—either through a licensed integrator or the Pakistan Revenue Automation Limited (PRAL)—conduct successful integration testing, and commence issuance of real-time electronic invoices by the stipulated cut-off dates. All such deadlines for registration, testing, and live invoicing have now lapsed across categories.

For taxpayers with annual turnover exceeding Rs1 billion (including importers), registration was due by October 15, 2025, integration testing by October 25, 2025, and issuance of electronic invoices from November 1, 2025 onwards.

Taxpayers with turnover below Rs100 million were required to register by November 15, 2025, complete testing by November 25, 2025, and begin electronic invoicing by December 1, 2025. Remaining categories had until December 10, 2025 for registration, with subsequent testing and invoicing deadlines falling later in December 2025.

This enforcement action forms a critical component of the FBR’s ongoing digitisation strategy aimed at modernising sales tax administration, enhancing real-time compliance monitoring, and curbing under-reporting through mandatory e-invoicing. Non-compliant entities now face the imminent imposition of prescribed penalties effective from January 2026.