Every sales-tax registered business in Pakistan was due to issue FBR e-invoices by 31 December 2025. If your invoices still go out without an FBR invoice number and QR code, reported penalties start at PKR 500,000, and your buyers may question their input tax. This guide explains FBR e-invoicing as of October 2026: the SROs, who is covered, the PRAL route, the Tier-1 POS regime, and what Odoo needs.
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What the FBR e-invoicing mandate requires
The legal base is section 23 of the Sales Tax Act, 1990, and Chapter XIV of the Sales Tax Rules, 2006. SRO 69(I)/2025, issued on 29 January 2025, rewrote that chapter. It requires every taxable supply by a notified person to carry a real-time, verifiable electronic invoice.
In practice, your system sends each invoice to FBR as it is issued, and FBR returns a unique FBR invoice number. That number, a QR code and the FBR Digital Invoicing logo then appear on the customer's invoice.
A scanned copy or a PDF exported from Excel is not an FBR e-invoice. The data must reach FBR in the structured format its API expects.
Who is covered and the deadlines that have passed
SRO 709(I)/2025 of 22 April 2025 extended the mandate to all sales-tax registered persons. SRO 1413(I)/2025 replaced its dates in August 2025. The schedule that now governs is SRO 1852(I)/2025 of 24 September 2025, which phased businesses in by type and turnover.
| Category | E-invoices required from |
|---|---|
| Public companies, companies above PKR 1 billion turnover, and importers | 1 November 2025 |
| Individuals and AOPs above PKR 100 million turnover | 1 November 2025 |
| Companies with PKR 100 million to 1 billion turnover | 15 November 2025 |
| Companies with turnover up to PKR 100 million | 1 December 2025 |
| All other registered persons | 31 December 2025 |
Each phase also had earlier registration and testing dates. Turnover is measured from your sales tax returns.
In 2026 there is no phase left to wait for. A newly registered business should integrate before its first invoice.
Penalties and the input tax risk
Press reports from September 2025 say FBR can impose PKR 500,000 for a first failure to integrate. Repeat failures reportedly rise to PKR 1 million, 2 million and 3 million. The rules themselves send contraventions to the penalty provisions of section 33 of the Sales Tax Act.
Reports in January 2026 said enforcement against companies that missed their phase would start that month. Advisers have also warned that buyers may struggle to claim input tax on unreported invoices.
Corrections are now tightly timed. Sales Tax General Order 01 of 2026 lets you cancel or edit a valid e-invoice issued in genuine error within 72 hours, through FBR's system. After that, you need prior approval from your Commissioner Inland Revenue.
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How FBR e-invoicing integration works through PRAL or a licensed integrator
Only a licensed integrator may connect your software to FBR. PRAL, FBR's own IT company, is a licensed integrator under the rules and must provide integration free of charge on request. Private licensed integrators may charge fees.
The PRAL route usually runs in four steps:
- Register on the Digital Invoicing portal and record your business activity and sector.
- Obtain a security token; PRAL's technical documentation says tokens are valid for five years.
- Pass the sandbox test scenarios that apply to your sector.
- Switch to production and post live invoices in real time.
Since General Order 01 of 2026, dated 30 March 2026, you may use more than one licensed integrator.
If you are planning this alongside a wider system change, our Odoo ERP implementation team can scope both together. It also helps to know the eight phases of an Odoo implementation before you commit to a date.
The separate POS regime for Tier-1 retailers
Tier-1 retailers carried a POS integration duty well before the wider e-invoicing mandate. Tier-1 is defined in the Sales Tax Act and covers, among others, chain-store units and shops in air-conditioned malls. Other tests use electricity bills and shop size, so check the current thresholds.
The rules require every sale to pass through an integrated POS, with a QR code printed on each receipt. Invoices issued during an outage must be marked offline and uploaded within 24 hours of the connection returning. Reported enforcement includes sealing of outlets and fines of up to PKR 500,000 or 200% of the tax involved.
FBR has also published draft income tax rules, SRO 288(I)/2026, that would extend integration to restaurants, clinics, schools and other services. Check whether they have been finalised before planning around them. Our guide to Odoo for multi-store retail explains how Odoo POS is structured across branches.
What your ERP needs for FBR e-invoicing
The FBR API is strict, and weak master data means rejected invoices. Your ERP must hold or produce:
- Seller and buyer identity: NTN or CNIC, business name, province and address for both parties.
- Buyer registration check: "Registered" or "Unregistered", confirmed through FBR's reference API, not typed by hand.
- Item data per line: HS code, a unit of measure FBR accepts for that HS code, quantity, value excluding tax, rate and tax amount.
- Tax treatment: sale type, plus SRO schedule and item serial where a reduced or exempt rate applies.
- Real-time posting: each invoice sent when it is confirmed, with FBR's response stored against it.
- Print output: the FBR invoice number, QR code and Digital Invoicing logo on the printed or PDF invoice.
- Debit notes: linked to the original FBR invoice reference.
FBR returns its own invoice number rather than the IRN used in some other countries. The idea is the same: the tax authority's reference becomes the invoice's legal identity.
How to connect Odoo to FBR e-invoicing
Odoo 19 includes a Pakistan fiscal localisation for the chart of accounts and taxes. Unlike Saudi Arabia, where Odoo ships its own ZATCA module, the FBR link comes through a connector. Third-party FBR Digital Invoicing modules for Odoo 19 are listed on the Odoo App Store, or a partner can build one against PRAL's API.
A sound setup adds HS code and FBR unit fields to products, and NTN, STRN and province to customers. It posts each confirmed invoice, shows rejections inside Odoo, and prints the FBR number and QR code.
Judge a connector the way you would judge any custom development in Odoo: who maintains it, whether it handles debit notes and sandbox scenarios, and whether it survives upgrades. Our integrations service covers exactly this kind of API work.
If you are still on Tally or spreadsheets, combine the moves. Our post on migrating from Tally to Odoo explains what to carry over, and clean HS codes and customer NTNs belong in that clean-up. Businesses that also sell into Saudi Arabia will recognise the pattern from ZATCA Phase 2.
Frequently asked questions
Is FBR e-invoicing mandatory for every sales-tax registered business?
Yes. Under SRO 709(I)/2025 and SRO 1852(I)/2025, all sales-tax registered persons were due to issue e-invoices by 31 December 2025.
Do I have to pay PRAL to integrate?
No. Under the Sales Tax Rules, PRAL must provide integration services free of charge on request. Your costs are ERP changes, the connector and any private integrator.
Can I edit an FBR e-invoice after it is issued?
Yes, within 72 hours and only for a genuine mistake, through FBR's system. After that you need prior approval from the Commissioner Inland Revenue.
Does Odoo support FBR e-invoicing?
Yes, through a third-party or partner-built connector on top of the Pakistan localisation. Test it in the PRAL sandbox first.
Next step
FBR e-invoicing is now part of issuing any taxable invoice in Pakistan. Our Karachi team and our finance and tax advisory consultants can review your invoice data, connector choice and go-live plan.
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Written by Hamza, an AI agent at C2P Consultants, and reviewed by our consulting team.