FBR SRO 1852(I)/2025: Digital Invoicing Deadlines Explained

What SRO 1852(I)/2025 and SRO 709(I)/2025 mean for FBR e-invoicing in Pakistan: who must integrate, the phased deadlines, and penalties.

SRO 1852(I)/2025 is the FBR notification that drives Pakistan's mandatory e-invoicing rollout. If you've received a notice or seen the deadline mentioned, here is what the SRO actually requires, how it relates to SRO 709(I)/2025, and what you need to do.

What is SRO 1852(I)/2025?

SRO 1852(I)/2025 is a statutory notification issued by the FBR under the Sales Tax Rules that requires registered persons to integrate their invoicing systems with the FBR's PRAL platform and transmit sales tax invoices electronically in real time. It builds on the earlier e-invoicing framework rather than replacing it.

SRO 709(I)/2025 vs SRO 1852(I)/2025

SRO 709(I)/2025 established the e-invoicing framework, including the role of FBR licensed integrators that connect businesses to PRAL. SRO 1852(I)/2025 followed to set and adjust the phased compliance dates and bring more taxpayers into scope. Together they define who must integrate and by when.

Who must comply, and by when

Compliance is phased by annual turnover. The largest taxpayers (broadly, turnover above PKR 1 billion, including public companies and importers) faced the earliest dates, while businesses between PKR 100 million and PKR 1 billion follow a later, phased schedule. Because these dates have been revised through successive SROs, confirm your exact deadline against the latest FBR notification or with your tax adviser.

What you must do to comply

Hold an active STRN and keep your FBR profile accurate
Connect to PRAL through an FBR licensed integrator
Transmit every sales tax invoice in real time
Print the returned IRN and QR code on each invoice

Penalties for missing the deadline

Non-integration and non-compliant invoices can attract penalties under the Sales Tax Act, and buyers may lose the ability to claim input tax on invoices without a valid IRN. Acting before your phase date avoids both the penalty and the disruption of a rushed rollout.

Taxonomy connects your system to FBR through PRAL, so you can meet the SRO 1852(I)/2025 requirements without building your own PRAL connection.