Quick answer
What is SRO 709(I)/2025?
SRO 709(I)/2025 is an FBR notification dated 22 April 2025, issued under Rule 150Q(2) of the Sales Tax Rules, 2006. It notified all corporate and non-corporate sales-tax-registered persons to integrate their invoicing systems with FBR's computerised system — through a licensed integrator — and issue electronic invoices. Its deadlines were later extended and re-phased by SRO 1413(I)/2025 and SRO 1852(I)/2025.
Key takeaways
- Dated 22 April 2025 and issued under Rule 150Q(2) of the Sales Tax Rules, 2006.
- Covers all corporate and non-corporate registered persons — not just FMCG sectors or Tier-1 retailers.
- Integration must be through an FBR-licensed integrator; PRAL provides this free.
- Original deadlines were extended; the final phased schedule came in SRO 1852(I)/2025.
- Works together with SRO 69(I)/2025, which set out the procedure in Chapter XIV.
What SRO 709(I)/2025 says
Rule 150Q of the Sales Tax Rules, 2006 lets FBR notify persons, or classes of persons, who must integrate with its computerised system for issuing and transmitting electronic invoices. Using that power, SRO 709(I)/2025 extended the requirement to the corporate and non-corporate sectors as a whole.
Before it, integration obligations were limited to specific groups — most visibly Tier-1 retailers under the POS regime and certain sectors notified earlier. After it, the question for most businesses changed from "does this apply to me?" to "how quickly can we integrate?"
Who it applies to
FBR's Digital Invoicing FAQs state that, as per SRO 709 dated 22 April 2025, electronic invoicing is mandatory for all corporate and non-corporate registered persons. In practice that covers manufacturers, importers, wholesalers, distributors, dealers and other persons registered under the Sales Tax Act, 1990.
What it requires
- Integrate your POS, ERP or other invoicing system with FBR's computerised system through an FBR-licensed integrator. PRAL does this free of cost.
- Issue electronic invoices in FBR's prescribed format, transmitted in real time.
- Print the FBR invoice number, QR code and Digital Invoicing logo on each invoice. QR code rules.
- Follow Chapter XIV of the Sales Tax Rules as substituted by SRO 69(I)/2025.
Deadlines under SRO 709 — and what replaced them
SRO 709 initially gave corporate registered persons very little time, which drew criticism from the business community. The dates were extended — FBR's FAQs list 1 June 2025 for corporate and 1 July 2025 for non-corporate registered persons — and then re-phased by business size, first by SRO 1413(I)/2025 and finally by SRO 1852(I)/2025, whose last category was scheduled to go live by 31 December 2025.
See the complete deadline timeline for every date.
Penalties for non-compliance
A person required to integrate who fails to do so is liable under Section 33 of the Sales Tax Act, 1990: Rs 500,000 for the first default, then Rs 1 million, Rs 2 million and Rs 3 million at 15-day intervals, followed by possible sealing of business premises. Since 1 July 2026, the Finance Act 2026 also allows FBR to suspend or blacklist the registration of non-integrated businesses.
How to comply with SRO 709
- 1
Register for digital invoicing in IRIS
Choose your licensed integrator and get your sandbox token. Guide.
- 2
Pick your invoicing software
Build an integration to PRAL's API or use ready-made software such as DInvoice.
- 3
Pass sandbox testing and go live
Complete the scenarios for your business activity, then switch to production.
Frequently asked questions
Is SRO 709(I)/2025 still in force?
Its core effect — that all corporate and non-corporate registered persons must integrate — continues. Its original deadlines were replaced by later phased schedules (SRO 1413(I)/2025 and SRO 1852(I)/2025).
Does SRO 709 apply to small businesses?
It applies to non-corporate registered persons too, so sole proprietors and AOPs registered for sales tax are covered. The later phased schedule simply gave smaller businesses later go-live dates.
What is the difference between SRO 709 and SRO 69?
SRO 69(I)/2025 sets out the procedure — Chapter XIV of the Sales Tax Rules on licensing, e-invoices and integration. SRO 709(I)/2025 uses Rule 150Q(2) to notify who must follow it: all corporate and non-corporate registered persons.
Sources
- FBR — Digital Invoicing FAQs
- Business Recorder — FBR extends new set of rules for e-invoicing (SRO 709)
- FBR — SRO 69(I)/2025: Sales Tax Rules, 2006, Chapter XIV (PDF)
- PKRevenue — Penalty up to Rs 3 million for failure to integrate business
- KPMG — Pakistan: Tax measures in Finance Act 2026
Published by DInvoice (Digital Invoice Integrator), FBR digital invoicing software for Pakistan. This page is general information, not legal or tax advice; rules and penalty amounts change, so confirm current requirements with FBR or your tax advisor. Last reviewed 26 September 2026.