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SRO 1852 Explained: Current FBR Electronic Invoicing Deadlines

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Short answer

SRO 1852(I)/2025 is the current FBR notification for phased electronic invoicing. It superseded SRO 1413 and set registration, testing and issuance dates by category, with the last group due by 31 December 2025. In 2026 those dates have passed, so covered businesses must already be issuing electronic invoices.

Start here: FBR e-invoicing rules 2026

S.R.O. 1852 (I)/2025 is the notification that (as of its issuance) superseded S.R.O. 1413 (I)/2025 and set the phased dates for sales tax registered persons to register, test, and issue electronic invoices through a licensed integrator or PRAL. Always open the PDF on FBR's download site - summary tables on blogs (including this one) are helpers, not law.

How did SRO 709, 1413 and 1852 replace each other?

  1. S.R.O. 709 (I)/2025 (22 April 2025) - made electronic invoicing mandatory for corporate and non-corporate registered persons. FBR's public FAQ still quotes 709's June/July 2025 dates in places; those are historical.
  2. S.R.O. 1413 (I)/2025 (1 August 2025) - superseded 709 and published a phased August–December 2025 table.
  3. S.R.O. 1852 (I)/2025 - expressly supersedes 1413 and replaces the table with later October–December 2025 milestones.

Download: SRO 1852 PDF.

What does SRO 1852 require?

For the category that matches your entity, 1852 requires you to complete registration, then testing for integration of hardware/software with FBR's computerized system through a licensed integrator or PRAL, and then issue electronic invoices not later than the date in the issuance column.

What are the SRO 1852 deadlines by category?

Confirm each cell against the official table. Broadly (registration / testing / issuance):

  • Public companies and companies with turnover above Rs 1 billion (excluding that public-company row): mid-October registration, late-October testing, electronic invoices from 1 November 2025.
  • Companies with turnover above Rs 100 million and up to Rs 1 billion: late-October registration / testing, electronic invoices from 15 November 2025.
  • Importers: mid/late November testing window, electronic invoices from 1 December 2025.
  • Individuals and AOPs with turnover above Rs 100 million: October testing milestones, electronic invoices from 1 November 2025 (per the SRO table).
  • Registered persons not listed above: December registration/testing, electronic invoices by 31 December 2025.

If you are reading this in 2026, those statutory issuance dates have already passed for covered categories. Late integration does not erase the obligation - FBR FAQs point to penalties under Section 33 of the Sales Tax Act, 1990 for non-compliance with Board timelines.

What should I do next?

  • Match your entity type and last-twelve-months sales tax turnover to the SRO table.
  • Complete IRIS Digital Invoicing registration and choose PRAL (free) or another licensed integrator.
  • Finish IP whitelisting and sandbox scenarios before production tokens.
  • Issue invoices that receive an FBR invoice number and print the required DI logo + QR on customer copies.

How Taxora.pk helps

Taxora.pk is software for create → PRAL validate → FBR post → QR PDF. It does not replace your IRIS registration or tax advisor. See how to connect PRAL, who must register, penalties and SRO 1413 history.

Common questions

Does SRO 1852 replace SRO 1413?

Yes. SRO 1852(I)/2025 expressly supersedes SRO 1413(I)/2025 and replaces its table of dates. Use 1413 only for historical context.

What if my SRO 1852 deadline has already passed?

The obligation still applies. FBR FAQs point to penalties under Section 33 of the Sales Tax Act, 1990 for missing Board timelines, so integrate as soon as possible and issue compliant invoices from then on.

Where is the official SRO 1852 PDF?

On FBR’s download site, linked in the references on this page. Blog summaries, including this one, are helpers; the PDF is the legal text.

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