Guide
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Who Must Integrate with FBR in Pakistan?
FBR integration originally applied only to Tier-1 retailers as defined in section 2(43A) of the Sales Tax Act 1990. SRO 709(I)/2025 extended electronic invoicing to all corporate and non-corporate sales-tax-registered persons, and SRO 288(I)/2026 added notified income tax categories including restaurants, marriage halls, courier services and medical practitioners.
Not tax advice — This guide is general information, not tax or legal advice. Pakistan's e-invoicing rules have been amended and their deadlines extended repeatedly since 2025, so the position may have changed since this page was last verified. Confirm your own obligations with FBR directly or with a qualified tax advisor before acting.
What is a Tier-1 retailer?
Tier-1 retailer is defined in section 2(43A) of the Sales Tax Act 1990, a definition introduced by the Finance Act 2017. A retailer falls into Tier-1 if they meet any one of the following categories — not all of them, any one.
- —A retailer operating as a unit of a national or international chain of stores
- —A retailer operating in an air-conditioned shopping mall, plaza or centre, excluding kiosks
- —A retailer whose cumulative electricity bill over the immediately preceding twelve consecutive months exceeds Rs 1,200,000
- —A wholesaler-cum-retailer engaged in bulk import and supply of consumer goods on a wholesale basis to retailers as well as on a retail basis to the general body of consumers
- —A retailer whose shop measures one thousand square feet in area or more
Note — Section 2(43A) has been amended several times since 2017, including changes to thresholds and categories. Read the current text of the Sales Tax Act rather than relying on any summary, including this one.
The electricity bill test catches people by surprise
Of the five categories, the twelve-month cumulative electricity bill exceeding Rs 1,200,000 is the one that pulls in businesses that do not think of themselves as large retailers. That is an average of Rs 100,000 a month across a year.
For an air-conditioned showroom, a cold-storage operation, or a shop running heavy refrigeration through a Punjab summer, that threshold is not exotic. It is also cumulative across the preceding twelve consecutive months, so a seasonal spike counts toward it.
The 2025 change: it is no longer just retailers
SRO 69(I)/2025, dated 29 January 2025, replaced Chapter XIV of the Sales Tax Rules 2006 with new rules covering the licensing of integrators, integration itself, and the issuance of electronic invoices.
SRO 709(I)/2025, issued on 22 April 2025, then extended electronic invoicing requirements to both corporate and non-corporate registered persons. In practice that moves the question from "am I a Tier-1 retailer?" to "am I registered for sales tax?" — which is a far larger population including manufacturers, wholesalers, importers and service providers with no retail counter at all.
SRO 288(I)/2026 and the income tax categories
On 18 February 2026 FBR issued SRO 288(I)/2026, replacing Chapter VIIA of the Income Tax Rules 2002. It requires notified enterprises to provide details of outlets, points of sale and e-invoicing transactions through FBR's online platform, and provides that no supply is to be made by an integrated enterprise except through systems connected to FBR's network.
The notified categories reported include:
- —Restaurants
- —Hostels, motels and guest houses
- —Marriage halls and marquees
- —Clubs, including race clubs
- —Inter-city road transport operators
- —Courier and cargo services
- —Personal care services such as beauty parlours and clinics
- —Medical practitioners including dentists and physiotherapists
- —Veterinary doctors
- —Pathological laboratories
So how do I know if this applies to me?
Work through it in this order. Are you registered for sales tax? If yes, the 2025 electronic invoicing rules are the first thing to check. Do you meet any single limb of the Tier-1 definition? If yes, the POS integration requirement applies regardless of size in other respects. Does your business appear in the SRO 288(I)/2026 categories? If yes, the income tax online integration rules apply on their own track.
And if you provide services in Punjab, check the Punjab Revenue Authority separately — sales tax on services is provincial, and PRA runs its own monitoring system.
This is a question worth putting to a tax advisor rather than resolving from a web page. The cost of asking is trivial next to the cost of guessing wrong.
Sources
Every factual claim on this page traces to one of the following. Where FBR publishes something directly, that is what we have used.
FAQ
Questions, answered.
Under section 2(43A) of the Sales Tax Act 1990, a retailer whose cumulative electricity bill during the immediately preceding twelve consecutive months exceeds Rs 1,200,000 falls within the Tier-1 definition. That works out to an average of about Rs 100,000 per month, and it is cumulative rather than a monthly test.
Yes, it can on its own. A retailer whose shop measures one thousand square feet in area or more falls within the Tier-1 definition under section 2(43A), independently of turnover, electricity usage or whether the shop is in a mall.
There is no blanket small-business exemption in the 2025 rules. SRO 709(I)/2025 extended electronic invoicing to both corporate and non-corporate registered persons, so the practical test is sales tax registration rather than size. Whether a specific small business is caught depends on its registration status and category — confirm with FBR or a tax advisor.
SRO 288(I)/2026 reportedly lists medical practitioners including dentists and physiotherapists, veterinary doctors and pathological laboratories among the categories required to integrate for income tax purposes. Personal care providers such as beauty parlours and clinics are also listed. Verify the current notified list with FBR.