If you run a registered business in Pakistan — retail, wholesale, manufacturing, or distribution — you have probably heard about FBR's new digital invoicing requirement. SRO 69(I)/2025 is the statutory regulation that makes electronic invoicing mandatory for tier-1 retailers and businesses registered under sales tax. This article explains exactly what it means, who it applies to, and what happens if you ignore it.
SRO 69(I)/2025 is a Statutory Regulatory Order issued by the Federal Board of Revenue (FBR) under the Sales Tax Act 1990. It expands and formalises Pakistan's digital invoicing mandate, requiring covered businesses to generate, validate, and electronically transmit sales invoices to FBR's PRAL gateway in real time at the point of sale.
The regulation builds on earlier SROs and the PRAL Technical Specification V1.12, which defines the exact data format, field requirements, and submission rules every invoice must follow. An invoice that does not comply with this specification is rejected by FBR's system — and a rejected invoice is treated as an unrecorded transaction.
SRO 69(I)/2025 applies to:
If you have an NTN and are registered for sales tax, check with your tax consultant whether you fall within scope. The safest assumption is that if FBR has previously asked you to install a fiscal device or connect to PRAL, you are required to comply with SRO 69(I)/2025.
FBR has begun issuing notices and penalties to non-compliant businesses. Under the Sales Tax Act 1990, penalties for failure to issue compliant invoices include:
The enforcement cycle has started. Businesses that received notices in early 2025 and did not respond are now facing escalated action.
Under PRAL Technical Specification V1.12, every invoice submitted to FBR must include:
Getting any one of these fields wrong — even a mismatch between the HS code and UoM — results in rejection. The rejection is logged against your NTN.
Panther FBR Enterprise V10.1 is built specifically around PRAL Technical Specification V1.12 and SRO 69(I)/2025. When you select a product and scenario, the software auto-fills the correct HS code, UoM, and tax rate — eliminating the most common source of rejections. Before submitting to FBR's gateway, every invoice is validated locally against FBR's rules. If something is wrong, you see the error before it reaches FBR.
The software works offline. You can build and review invoices without an internet connection — you only need connectivity at the moment of submission to FBR's gateway. This is critical for retailers in areas with unreliable connectivity.
If you are not yet compliant with SRO 69(I)/2025, take these steps immediately:
Panther FBR Enterprise V10.1 covers every step after obtaining your credentials. The 7-day free trial gives you full access to all 28 scenarios and FBR sandbox connectivity at no cost and without requiring a credit card.
Download the free trial at fbr.pecsglobal.com or contact us on WhatsApp at +92 307 3812493 if you have questions about your specific situation.