SRO 1852 Explained: Current FBR Electronic Invoicing Deadlines

S.R.O. 1852 (I)/2025 is the notification that (as of its issuance) superseded S.R.O. 1413 (I)/2025 and set the phased dates for sales tax registered persons to register, test, and issue electronic invoices through a licensed integrator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.

Notification chain (do not use the FAQ dates alone)

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 S.R.O. 1413 (I)/2025 (1 August 2025) — superseded 709 and published a phased August–December 2025 table.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 every row requires

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.

Indicative category milestones under SRO 1852

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.

Practical next steps

• 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 and SRO 1413 history.