Pakistan’s FBR has expanded the electronic invoicing framework to cover federal excise duty and Islamabad’s services tax, allowing businesses to use a single invoice for multiple tax types while extending existing integration requirements, record-retention rules and penalties for non-compliance.
Pakistan’s Federal Board of Revenue (FBR) of Pakistan has issued notifications S.R.O. 1666(I)/2026 and S.R.O. 1667(I)/2026 on 29 September 2026, to extend the national electronic invoicing framework beyond standard sales tax to cover Federal Excise Duty (FED) and Islamabad Capital Territory (ICT) services tax.
These updates establish that businesses required to issue electronic invoices under the Federal Excise Act or the Islamabad Capital Territory Ordinance must comply with the established digital integration protocols of the Sales Tax Rules. Furthermore, transactions subject to multiple tax types can utilise a single electronic invoice that clearly categorises each distinct tax or duty.
The key measures are as follows:
Statutory framework & expanded scope
- Sales tax rules amendment: S.R.O. 1666(I)/2026 amends the Sales Tax Rules, 2006 under Section 50 of the Sales Tax Act, 1990 and Section 40 of the Federal Excise Act, 2005. It integrates FED under the Federal Excise Act, 2005 and taxable services under the Islamabad Capital Territory (Tax on Services) Ordinance, 2001 into Chapter XIV of the Sales Tax Rules, 2006.
- Federal excise rules amendment: S.R.O. 1667(I)/2026 amends the Federal Excise Rules, 2005 by inserting Rule 12A (“Electronic invoicing and integration”).
- Unified compliance standard: System integration, invoice generation, transmission, validation, issuance, storage, verification, debit and credit notes, advance receipt invoices, offline invoicing, and technical mandates now apply mutatis mutandis across all three tax regimes.
Elimination of duplicate technical setup
Businesses already integrated for sales tax under Chapter XIV of the Sales Tax Rules, 2006, are deemed integrated for electronic invoicing under the Federal Excise Act, 2005, and Islamabad’s tax on services. They do not need separate software or API integration, and existing integrator licences automatically cover both taxes without requiring additional licences.
Single unified electronic invoice & new data fields
- Single document multi-tax invoicing: Where a transaction incurs sales tax, federal excise duty, and ICT services tax simultaneously, a single electronic invoice containing separately identifiable details for each levy satisfies the legal requirements of all relevant laws.
- Mandatory FED particulars: S.R.O. 1666(I)/2026 inserts specific line-item data requirements into Rule 150R(13) for federal excise items:
- Federal Excise Duty Type
- Federal Excise Duty Rate
- Price per unit for Federal Excise Duty
- Federal Excise Duty Amount (payable otherwise than in sales tax mode)
- Applicable SRO/Schedule reference
- Applicable SRO/Schedule Serial number
- Secure transmission: Invoice records must be securely transmitted to FBR systems with data explicitly tagged and identifiable by tax type and payment mode.
Record keeping, audits, and penalties
Businesses must electronically issue and retain invoices, debit notes, credit notes, and advance receipt invoices for six years. The common e-invoicing system does not change existing rules for the assessment, collection, payment, adjustment, or reporting of federal excise duty, and audits and inspections remain governed by the relevant tax laws. Sellers that fail to issue invoices containing an FBR invoice number or QR code, or omit sales from Annex-C or tax returns, may face recovery of unpaid taxes or duties and statutory penalties.
