Pakistan e-Invoicing Mandate

This guide provides an overview of e-Invoicing requirements in Pakistan, including the legal framework, the use of the Federal Board of Revenue (FBR) e-Invoicing system, compliance obligations, and key reporting considerations. It is intended to assist businesses that issue or receive invoices for transactions subject to Pakistani Sales Tax (ST).

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Tax Authority

Federal Board of Revenue

Mandate Go-Live Date

1 November 2025

Digital Signature

Not required

Archiving

Mandatory - 5 Years

Invoice Format

JSON based format as per FBR’s prescribed schema

Pakistan introduced mandatory e-invoicing as part of its broader digital tax reform agenda led by the Federal Board of Revenue (FBR). The system was initially rolled out in 2021, targeting large-scale manufacturers with annual turnover exceeding PKR 100 million. The mandate requires notified taxpayers to integrate their ERP/POS systems with the FBR’s Invoice Management System (IMS) via the Tax Asaan Portal.

 

Pakistan operates a centralised clearance Continuous Transaction Control (CTC) model, where invoices must be submitted in structured JSON format for real-time validation. Once validated, the FBR issues an Invoice Reference Number (IRN), UUID, QR code, and digital signature before the invoice can be legally issued. The scope is expanding in phases, with additional sectors notified by the FBR.

Mandate Details
Mandate Status
Which types of transactions must be reported via e-Invoicing?
mandatory

Effective: November 2025

Live (Phased approach since 2021)
 
Applies to VAT-registered businesses specifically notified by the FBR (not a blanket requirement).

B2G

B2B:
1) Mandatory for notified taxpayers (currently May - Corporate registered persons; June - Non-Corporate registered persons). 1 Sept 2025 - all public companies, all companies excl. at serial no. 1 with turnover exceeding 1 billion rupees declared in sales tax returns for the last twelve months and all importers.

2) 1 Oct 2025 - All companies excl. at serial no. 1 with turnover exceeding 100 million rupees but not exceeding 100 billion rupees declared in sales tax returns for last 12 months; all individuals and association of persons with turnover exceeding 100 million rupees declared in sales tax returns for the last 12 months.

3) 1 Nov 2025 - All companies excluding at serial no. with turnover not exceeding 100 million rupees declared in sales tax retums for the last twelve months.

4) 1 Dec 2025 - Registered persons other than listed above.

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B2C:
Abbreviated invoices permitted for transactions ≤ PKR 100,000.

Full standard invoice required for transactions > PKR 100,000.

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Cross-border:
Domestic and cross-border invoice flows require integration and validation via FBR for notified taxpayers.

Export invoicing is not routed via IRIS for pre-clearance but subject to FBR oversight.

Intra-community transactions

Export & import cross-border transactionsf

Transport/shipping transactions

Are there any thresholds that determine e-Invoicing applicability?

  • Yes.
     
    Initial phase (2021): Manufacturers with turnover > PKR 100 million.
    B2C simplified invoice allowed for transactions ≤ PKR 100,000 (inclusive of tax).
    Above PKR 100,000 → full standard invoice required.
     
    Mandate applies only to taxpayers notified by FBR.
  • Taxpayers who adopt the flat-rate regime
  • Third sector entities with revenue/fees of EUR 65,000 and over
  • Microenterprises with revenue/fees of EUR 25,000 and over
  • All taxable persons, residents or established, in Italy if their annual revenue is above EUR 25,000
  • Amateur sports associations

What are the implementation dates of the e-invoicing mandate?

Transaction Type
1 Nov 2025 (Tiers 1 & 2)
15 Nov 2025 (Tier 3)
1 Dec 2025 (Tier 4)
31 Dec 2025 (Final Phase)
2030 (EU ViDA)
Local - B2G (Public)
*
**
***
N/A
Local - B2B (Domestic)
*
**
***
N/A
Local - B2C (Domestic)
*
**
***
N/A
Local - Cross-border reporting
*
**
***
N/A
Foreign - B2B/B2C (non-established)
*
**
***
N/A
Mandatory e-invoicing in effect
*
Applies to Tier 1 & Tier 2 taxpayers
**
Applies to Tier 3 taxpayers
***
Applies to Tier 4 taxpayers
N/A
EU ViDA not applicable
Do I need to have a permanent establishment in Pakistan to be required to e-invoice?
The obligation applies to VAT-registered taxpayers notified by the FBR.
 
Domestic businesses:
Manufacturers and other notified sectors must comply once notified.
 
Foreign suppliers:
Foreign suppliers without physical presence or VAT registration in Pakistan are not required to comply.
 
Local subsidiaries/branches of foreign companies:
If you are registered for VAT in Pakistan and within a notified sector or turnover threshold, you are subject to the mandate.

While a formal "permanent establishment" is a common trigger for registration, the overarching requirement is being a registered person with the FBR. If you are importing or selling goods in Pakistan and are required to be registered for Sales Tax, you must issue e-invoices, regardless of whether you have a physical office, provided you fall under the specified turnover or business categories.

Yes. The mandate applies to VAT-registered businesses notified by the FBR.


B2G & B2B: Applies to notified VAT-registered manufacturers and sectors.
Foreign non-registered suppliers: Not required to comply.

Real-time reporting required. Invoices must be generated and uploaded to the IMS before supply or at the time of supply for validation and issuance of IRN/UUID.

Under the Sales Tax Act, 1990 and Sales Tax Rules, 2006: Failure to issue e-invoice: PKR 5,000 or 3% of tax involved (whichever is higher).

Failure to maintain records: penalty generally 1% of transaction value.

Repeated or deliberate non-compliance may result in: Suspension of sales tax registration, recovery proceedings, sealing of business premises (Section 48)

Steps to be performed by customer

1. Confirm whether business is notified by FBR and falls within applicable sector/turnover threshold.
2. Register and onboard via the Tax Asaan Portal and Invoice Management System (IMS).

Steps VAT IT can assist with

3. Integrate ERP/POS system with FBR via licensed integrator or PRAL using prescribed JSON schema.
4. Generate structured JSON invoice and transmit in real-time to IMS for validation.
5. Obtain IRN, UUID, QR code, and FBR digital signature before issuing invoice to buyer.
6. Implement compliant electronic archiving and retain invoices for minimum 6 years.

FAQs

Term 1 | Reclaim

Staying compliant involves understanding local VAT regulations in different countries, maintaining accurate records, and using the right documentation. VAT IT offers expertise in these areas, ensuring that your VAT reclaim processes align with regulations in each jurisdiction.

Staying compliant involves understanding local VAT regulations in different countries, maintaining accurate records, and using the right documentation. VAT IT offers expertise in these areas, ensuring that your VAT reclaim processes align with regulations in each jurisdiction.

Staying compliant involves understanding local VAT regulations in different countries, maintaining accurate records, and using the right documentation. VAT IT offers expertise in these areas, ensuring that your VAT reclaim processes align with regulations in each jurisdiction.

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