Electronic invoicing in Pakistan

Mandatory Adoption

The FBR has established a phased rollout of the e-invoicing system:

• July 1, 2025: Corporate taxpayers (legal entities) must be connected to the system.
• August 1, 2025: Non-corporate taxpayers must register and integrate.
• September 1, 2025: Mandatory for state-owned enterprises, importers, and businesses with annual turnover exceeding PKR 1 billion (≈ EUR 3 million).
• October 1, 2025: Mandatory for businesses and individuals with annual revenues between PKR 100 million and PKR 1 billion.
• November 1, 2025: Mandatory for businesses with revenues below PKR 100 million.
• December 1, 2025: General application to all remaining taxpayers.

Invoice Format

Electronic invoices in Pakistan must be issued in a standardized digital format defined by the FBR. The official structure is JSON (JavaScript Object Notation), which is the sole format accepted for submission and integration with the government platform.

Electronic Signature

In Pakistan, the e-invoice is not digitally signed by the issuer using its own certificate. Instead, the digital signature is generated by the FBR during the clearance process.

Once the invoice is transmitted to the FBR portal, the tax authority validates the data, and if compliant, digitally signs the invoice with its official certificate. This means every Pakistani e-invoice carries the FBR’s digital seal, ensuring its authenticity and fiscal validity. Alongside the signature, the FBR system assigns a unique QR code and UUID to each invoice, which are returned in the clearance response.

Archiving

All taxpayers are required to store their electronic invoices for a minimum of six years in a secure electronic format. Such archiving must comply with the technical specifications set by the FBR.

Tax Oversight

The implementation of e-invoicing provides the FBR with significantly enhanced real-time audit and control capabilities. Every invoice generated by a taxpayer is validated instantly by the FBR system, ensuring that each sales transaction is immediately recorded in the government’s tax database.

Real-time transmission and the assignment of a unique FBR invoice identifier (UUID) to each document prevent duplication or tampering, as every invoice is uniquely registered in the central system.

Process Flow 

The e-invoicing framework in Pakistan operates under a centralized clearance scheme. The workflow from issuance to archiving is as follows:

1. Generation and Transmission: The taxpayer creates the sales invoice in its system (including all mandatory data) and submits it in JSON format via the official FBR API in real time.
2. Validation by the FBR: The central FBR platform receives the e-invoice and validates its content. If compliant with tax regulations, the FBR grants clearance: it issues a unique invoice number, digitally signs the document, and appends the QR code and UUID. The cleared invoice is then returned to the issuer together with an acceptance message.
3. Delivery and Archiving: Once validated, the e-invoice obtains full legal effect. Both the issuer and recipient must retain the electronic invoice within their document management or tax archiving systems.