Pakistan's Federal Board of Revenue has proposed a sweeping electronic invoicing framework that would require businesses across a broad range of sectors — from restaurants and private hospitals to retailers and courier services — to integrate with its computerised system for real-time sales reporting.
Pakistan’s Federal Board of Revenue (FBR) has issued the draft notification S.R.O. 288(I)/2026 on 18 February 2026, which proposes a comprehensive framework for the online integration of businesses. This framework requires “integrated enterprises” to link their electronic invoicing hardware and software with the FBR’s computerised system for real-time reporting of sales.
Key requirements for electronic invoicing
Under the proposed rules, every integrated enterprise must issue a real-time verifiable electronic invoice or bill for every taxable supply and service. The system must be capable of:
- Generating and recording digital signatures on every invoice or bill.
- Generating unique QR codes (dimensions 7X7MM) based on a unique FBR invoice number and printing them on receipts.
- Transmitting data securely to the Board’s computerised system to receive a unique FBR invoice or bill number.
- Recording all adjustments, modifications, or cancellations while maintaining detailed activity logs.
Specified sectors and scope
The draft identifies a wide range of sectors in its Schedule that are required to integrate, including:
- Service providers: Restaurants, hotels, guest houses, marriage halls, and clubs (generally those with air conditioning).
- Healthcare: Medical service providers with fees over PKR 500, pathological laboratories, and private hospitals.
- Professionals: Accountants (Chartered and Cost & Management Accountants), photographers, and event managers.
- Retailers: Specifically, those part of national/international chains, located in air-conditioned malls, having annual electricity bills exceeding PKR 1.2 million, or having shops larger than 1,000 square feet.
- Others: Courier services, inter-city travel (air-conditioned or large fleets), health clubs, foreign exchange dealers, and private educational institutions with fees over PKR 1,000 per month.
Record retention and audit access
Integrated enterprises are required to retain electronic records for six years. The framework mandates that these documents be stored in a way that the original transmission can be recreated during a departmental audit. Furthermore, businesses must provide authorised Officers of Inland Revenue with access to their premises and all records for audit purposes. The FBR also intends to establish an Inland Revenue Enforcement Network to conduct physical checks and verify real-time reporting.
Licensing regime for integrators
The notification introduces a licensing regime where only licensed entities can provide integration software to notified taxpayers.
- License validity: Licenses are valid for five years, are non-transferable, and require a minimum paid-up capital of PKR 10 million from the applicant.
- PRAL’s role: Pakistan Revenue Automation Limited (PRAL) will act as a licensed integrator and is mandated to provide free-of-cost integration services and software to taxpayers on demand.
- Responsibilities: Licensees are responsible for the installation, configuration, and maintenance of the system, including safe and secure real-time data transmission to the FBR database.
