SRO 1852(I)/2025 and SRO 1413(I)/2025, explained
Both notifications set the dates for FBR digital invoicing in 2025. SRO 1852 replaced SRO 1413 and is the one in force. Here is what each says, which group you are in, and what it means for your business today.

What SRO 1852(I)/2025 says
FBR issued SRO 1852(I)/2025 on 24 September 2025. It tells every business registered for sales tax to do three things by set dates:
- Register its systems for integration with FBR.
- Test its hardware and software with FBR's system.
- Issue electronic invoices from then on.
The connection has to go through PRAL, FBR's own IT company, or a licensed integrator. Every business falls into one of seven groups, and each group has its own three dates.
The notification is made under section 50 of the Sales Tax Act 1990 and rule 150Q(2) of the Sales Tax Rules 2006. Its first line says it replaces SRO 1413(I)/2025.
The SRO 1852 dates, group by group
These are the dates as FBR issued them. "By" means not later than that date.
| Group | Who | Register by | Test by | E-invoices by |
|---|---|---|---|---|
| 1 | All public companies | 15 Oct 2025 | 25 Oct 2025 | 1 Nov 2025 |
| 2 | Other companies with turnover above Rs 1 billion | 15 Oct 2025 | 25 Oct 2025 | 1 Nov 2025 |
| 3 | All importers | 15 Oct 2025 | 25 Oct 2025 | 1 Nov 2025 |
| 4 | Other companies with turnover from Rs 100 million to Rs 1 billion | 25 Oct 2025 | 31 Oct 2025 | 15 Nov 2025 |
| 5 | Other companies with turnover up to Rs 100 million | 15 Nov 2025 | 25 Nov 2025 | 1 Dec 2025 |
| 6 | Individuals and AOPs with turnover above Rs 100 million | 10 Oct 2025 | 25 Oct 2025 | 1 Nov 2025 |
| 7 | Everyone else registered for sales tax | 10 Dec 2025 | 25 Dec 2025 | 31 Dec 2025 |
Turnover is what you declared in your sales tax returns for the last twelve months. "Other companies" means companies that are not public companies.
Which group are you in?
- A public company: group 1, whatever your turnover.
- Any other company, such as a private limited company: group 2, 4 or 5, by turnover. Above Rs 1 billion is group 2, Rs 100 million to Rs 1 billion is group 4, and up to Rs 100 million is group 5.
- An importer: group 3.
- An individual or an AOP (an association of persons, such as a partnership firm) with turnover above Rs 100 million: group 6.
- Anyone else registered for sales tax, such as a smaller sole trader or partnership: group 7.
The biggest businesses went first. Group 7 had the most time, and its last date was 31 December 2025.
What SRO 1413(I)/2025 said
SRO 1413(I)/2025 came first, on 1 August 2025. It replaced FBR's first timetable, SRO 709(I)/2025 of 22 April 2025. It used the same seven groups and the same three steps, but its dates were much earlier: the first groups had to issue e-invoices from 1 September 2025.
| Group | Who | Register by | Test by | E-invoices by |
|---|---|---|---|---|
| 1 | All public companies | 10 Aug 2025 | 25 Aug 2025 | 1 Sep 2025 |
| 2 | Other companies with turnover above Rs 1 billion | 10 Aug 2025 | 25 Aug 2025 | 1 Sep 2025 |
| 3 | All importers | 10 Aug 2025 | 25 Aug 2025 | 1 Sep 2025 |
| 4 | Other companies with turnover from Rs 100 million to Rs 1 billion | 10 Sep 2025 | 30 Sep 2025 | 1 Oct 2025 |
| 5 | Other companies with turnover up to Rs 100 million | 10 Oct 2025 | 30 Oct 2025 | 1 Nov 2025 |
| 6 | Individuals and AOPs with turnover above Rs 100 million | 10 Sep 2025 | 30 Sep 2025 | 1 Oct 2025 |
| 7 | Everyone else registered for sales tax | 10 Nov 2025 | 30 Nov 2025 | 1 Dec 2025 |
Less than two months later, SRO 1852 replaced it and gave every group more time. So if you see these earlier dates quoted somewhere, they are out of date.
SRO 1413 vs SRO 1852: how the dates moved
The date to start issuing e-invoices, in each version:
| Group | Who | SRO 1413 | SRO 1852 | Extra time |
|---|---|---|---|---|
| 1 | Public companies | 1 Sep 2025 | 1 Nov 2025 | 2 months |
| 2 | Companies above Rs 1 billion | 1 Sep 2025 | 1 Nov 2025 | 2 months |
| 3 | Importers | 1 Sep 2025 | 1 Nov 2025 | 2 months |
| 4 | Companies, Rs 100 million to Rs 1 billion | 1 Oct 2025 | 15 Nov 2025 | 6 weeks |
| 5 | Companies up to Rs 100 million | 1 Nov 2025 | 1 Dec 2025 | 1 month |
| 6 | Individuals and AOPs above Rs 100 million | 1 Oct 2025 | 1 Nov 2025 | 1 month |
| 7 | Everyone else | 1 Dec 2025 | 31 Dec 2025 | 1 month |
Every group gained between one and two months. The order stayed the same: public companies, the largest companies and importers first, everyone else last.
From SRO 709 to SRO 1852
- 29 January 2025: SRO 69(I)/2025 rewrote Chapter XIV of the Sales Tax Rules, the chapter that holds the e-invoicing rules.
- 22 April 2025: SRO 709(I)/2025 set the first timetable. Read SRO 709 explained.
- 1 August 2025: SRO 1413(I)/2025 replaced it.
- 24 September 2025: SRO 1852(I)/2025 replaced SRO 1413. Its dates are the ones that count.
- 31 December 2025: the last SRO 1852 date passed.
- 2026: FBR brought in more groups, such as federal excise and Islamabad service providers. Read SRO 1666 explained.
For every date in one place, including the 2026 ones, see the FBR digital invoicing deadlines.
Missed the date? What to do now
Every date in SRO 1852 has passed. If you are registered for sales tax and still not issuing e-invoices, you are late, and waiting costs more:
- Fines: up to Rs 1 million for not integrating, up to Rs 5 million more if you are still not integrated a month later, and possible sealing.
- Your buyers: registered buyers can claim input tax only on invoices FBR can match. Since 1 July 2026, unmatched input tax can cost them a further 20%. See the 2026 penalties.
Getting live takes four steps:
- Get IRIS access and sign up for digital invoicing inside IRIS. See FBR IRIS login and registration.
- Choose your connection: PRAL or a licensed integrator. See PRAL, integrator or software.
- Pass FBR's sandbox tests on FBR's test system. See from sandbox to go-live.
- Go live and send every invoice to FBR as you make it.
eInvoicePro is PRAL integrated. Make a sales tax invoice, send it to FBR, and get FBR's invoice number and QR code back right away, ready to print. More than 2,000 businesses use it, and over 1,000,000 invoices have gone through it. See the FBR digital invoicing software.
FAQs
What is SRO 1852(I)/2025? It is FBR's notification of 24 September 2025 that set when each group of sales tax registered businesses had to register, test and start issuing electronic invoices, through PRAL or a licensed integrator. It replaced SRO 1413(I)/2025.
Is SRO 1413(I)/2025 still in force? No. SRO 1852(I)/2025 replaced it on 24 September 2025, so its dates no longer apply.
What was the last date under SRO 1852? 31 December 2025, for registered persons not in any named group. Every other group had an earlier date.
Which turnover decides my group? The turnover you declared in your sales tax returns for the last twelve months.
Do I need a licensed integrator? The SRO says the connection must go through PRAL or a licensed integrator, so either works. eInvoicePro is PRAL integrated.
I missed my date. What happens now? You are late. A business that should be integrated and is not can be fined up to Rs 1 million, up to Rs 5 million more if it is still not integrated a month later, and can be sealed. Integrate as soon as you can.
Where can I read SRO 1852 and SRO 1413? Both are on FBR's website. The links are in the sources at the end of this post.
Related reading: the FBR digital invoicing deadlines, SRO 709 explained and the 2026 penalties.
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