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FBR compliance

Which FBR SRO Applies to Your Business? (2026)

FBR has issued several SROs on digital invoicing and POS integration. A plain map of 69, 709, 1413, 1852, 428 and draft 288, and how to check yours.

Sources: 5

Why FBR keeps issuing new SROs

If you've tried to research FBR digital invoicing on your own, you've probably run into a wall of SRO numbers (69, 709, 1413, 1852, 428, 288), each cited by a different blog, sometimes contradicting the last. That's not you failing to understand tax law; it's because FBR has been building this regime in layers since early 2025, and some explainers online collapse the layers into one story that isn't quite accurate.

There are, in fact, two separate regimes running in parallel, plus a set of amendment SROs that move dates around within each one. Once you see the split, most of the confusion disappears.

The base rule is SRO 69(I)/2025, which rewrote Chapter XIV (rules 150Q to 150XQ) of the Sales Tax Rules 2006 under Section 50 of the Sales Tax Act 1990. This is the SRO that creates the sales-tax obligation for registered persons to report invoices to FBR through the digital invoicing system. Ask your tax advisor how it applies to you.

SRO 69 didn't set a single go-live date for everyone — that came later, through a sequence of amendment notifications: SRO 709(I)/2025, then SRO 1413(I)/2025, and then SRO 1852(I)/2025, each revising the phased schedule by turnover bracket and entity type. SRO 1852(I)/2025 is the schedule most commonly cited as current at the time of the last review. Confirm against fbr.gov.pk before you rely on a specific date, because FBR has revised this stack more than once.

This whole track — 69 as the root, 709/1413/1852 as the phasing — governs one thing: real-time digital invoice reporting under the Sales Tax Act. Our FBR Compliance Hub walks through what a compliant invoice actually needs to contain once you're in scope.

The Income Tax track: SRO 428(I)/2024 and draft SRO 288(I)/2026

The second regime is easy to mistake for the first, because it also talks about "integration" and "real-time reporting", but it sits in a different law. The final instrument is SRO 428(I)/2024 (22 March 2024) under the Income Tax Rules 2002, which covers POS integration on and after 1 July 2024 for the business types in its schedule.

SRO 288(I)/2026 (18 February 2026, "Online Integration of Businesses") is a draft under the same chapter. It proposes a longer list of business types. FBR had not issued a final notification at the time of the last review, so the draft does not replace SRO 428(I)/2024 today. Our explainer on the draft covers what it proposes.

That distinction matters: the Sales Tax Act track is about invoice-level reporting, while the Income Tax track is about integrating your point-of-sale system. Which one applies to you is a question for your tax advisor.

Why treating these as one regime is the mistake

Many third-party guides blend the sales-tax SROs and the Income Tax POS SROs into a single "FBR e-invoicing" story with one deadline. That shorthand can lead you to the wrong conclusion about your own business. A retailer, for instance, can be a sales-tax-registered supplier issuing invoices (SRO 69/1852) and also a retail point of sale under the POS track. A services business that is not sales-tax registered might only need to look at the POS track. Ask your tax advisor.

Knowing which track — or both — applies to you changes what you actually need from your invoicing or POS software, and how urgently.

A simple decision tree

Ask yourself three questions:

  1. Are you registered for sales tax? If yes, you're in scope for the Sales Tax Act digital-invoicing track (SRO 69/709/1413/1852), and your go-live date depends on your turnover bracket and entity type — see our full deadline timeline.
  2. Is your business type named in SRO 428(I)/2024's schedule? Your tax advisor can confirm this. If yes, the Income Tax POS-integration track may apply regardless of your sales-tax status. Draft SRO 288(I)/2026 is not yet a final notification, so do not plan around it as if it were.
  3. Both "yes"? Plan for both. They are separate, and compliance with one doesn't cover the other. Penalties apply for failing to integrate; see the FBR compliance hub for the statutory text and our penalties explainer, and ask your tax advisor.

Where to check your exact date

Neither SRO stack is static. FBR has amended the sales-tax track more than once, and the draft on the Income Tax side may change before any final notification. Rules for healthcare are publicly contested. Before you commit to a compliance timeline, confirm your specific date and obligation at fbr.gov.pk and with your tax advisor.

Tasdeeq by Aboha is live today for counter receipts that carry an FBR invoice number and QR code. Aboha Digital Invoicing is coming soon. Questions about your setup? Contact us.

Frequently asked questions

Is SRO 288(I)/2026 the same as the digital invoicing law?

No. SRO 288(I)/2026 is a draft that concerns the Income Tax Rules' POS chapter (Chapter VIIA) and has not been issued as a final notification. Digital invoicing under the Sales Tax Act runs on a separate SRO 69(I)/2025 and SRO 1852(I)/2025 track. Ask your tax advisor which apply to you.

Which SRO is currently controlling the go-live schedule?

SRO 1852(I)/2025 is the schedule most commonly cited as current for Sales Tax Act digital invoicing at the time of the last review. Confirm against fbr.gov.pk, since FBR has revised this stack more than once.

Do I need to check both tracks even if I'm not sales-tax registered?

Possibly. The POS integration track under the Income Tax Rules (SRO 428(I)/2024, the final instrument) is separate from sales-tax registration. Ask your tax advisor whether your business type is named.

What happens if I only comply with one track when both apply?

Compliance under one regime does not satisfy the other. Each has its own reporting mechanics, so a business in scope for both needs to address both separately.

Sources

  1. SRO 69(I)/2025 — legal root (Section 50, Sales Tax Act 1990 + Chapter XIV, rules 150Q–150XQ, Sales Tax Rules 2006)
  2. FBR Digital Invoicing FAQs
  3. SRO 428(I)/2024 (22 Mar 2024) — final notification on POS integration under the Income Tax Rules
  4. Draft SRO 288(I)/2026 (18 Feb 2026) — FBR
  5. KPMG Pakistan tax alert, Mar 2026

This article is informational and is not tax or legal advice. Confirm your specific obligations with FBR or your tax advisor.

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