FBR Digital Invoicing for Commission Agents and Arhtis in Fruit, Vegetable and Grain Mandis (2026): Whose Invoice Is It?
An arhti sells someone else's goods. Whose FBR invoice is it, why exempt produce still needs one, and why your commission is taxed by the province.
The short version
This page is for commission agents in a sabzi mandi, fruit mandi or anaj mandi. It answers three questions: whose invoice is a mandi sale, whether exempt produce needs an FBR invoice, and who taxes your commission.
An arhti runs two businesses at one table. He sells other people's produce, and he charges a commission for doing it. Those two things are taxed by two different governments, and mixing them up is the mistake that costs money.
Fresh fruit, vegetables, eggs, live animals and unprocessed grain are exempt under the Sixth Schedule of the Sales Tax Act 1990. But exempt does not mean invisible. FBR Sales Tax Circular 01 of 2026 settled that. A registered and notified business must send even an exempt sale to FBR as a digital invoice.
Your commission is not goods. It is a service. Services are taxed by your province, not by FBR.
Two businesses at one table
Think of a normal shopkeeper. He buys goods, he owns them, he sells them, he keeps the profit. One business, one set of books.
An arhti does not work that way. A grower brings ten maunds of onions. You find a buyer, you handle the weighing and the money, and you take a cut. The onions were never yours.
So there are two separate money flows. The first is the sale of the onions, and that sale belongs to the grower. The second is your commission, and that one is yours.
Tax law follows ownership, not the table the deal happened on. That single idea decides everything below.
Some arhtis also buy on their own account, which traders call pakka arhat. When you buy the crop yourself and resell it, you own those goods, and that is a normal trading sale in your own name. Many mandi businesses do both in the same week. Keep the two apart in your records from day one, because FBR treats them differently.
Exempt produce still needs an invoice
This is the part most mandi businesses get wrong.
Fresh fruit and vegetables carry no sales tax. Neither do eggs, live animals, meat, fish or unprocessed cereals. They sit in the Sixth Schedule of the Sales Tax Act 1990, which is the list of exempt goods.
Traders then assume that no tax means no paperwork. That was roughly true before. It is not true now.
FBR Sales Tax Circular 01 of 2026 made the position plain. A business registered for sales tax and notified to integrate must issue a digital invoice for every supply. Exempt supplies are included. The invoice goes to FBR first. It comes back with an IRN (Invoice Reference Number — the unique number FBR gives each accepted invoice) and a QR code. Only then does it go to the buyer.
An exempt sale is posted under scenario SN006. The rate field says Exempt, the sales tax amount is zero, and the extra tax field is left empty. The tax is nil. The record is not.
Flour mills and rice mills hit exactly the same wall, and 'FBR Digital Invoicing for Flour Mills & Rice Mills: Why Exempt Still Means You Must Invoice (2026)' works through it with the same exempt goods.
One thing this does not do: being exempt does not by itself force you to register for sales tax. A business dealing only in exempt goods is generally not required to register. The duty to issue digital invoices starts once you are registered and FBR has notified you. 'Sales Tax Registration (STRN) in Pakistan: The Step Before FBR Digital Invoicing (2026)' explains where that line falls.
Your commission is a service, so FBR is the wrong door
Selling onions is goods. Arranging the sale of somebody else's onions is a service.
In Pakistan, sales tax on goods belongs to the federal government, which means FBR. Sales tax on services belongs to the provinces. Punjab has the PRA, Sindh has the SRB, Khyber Pakhtunkhwa has the KPRA, and Balochistan has the BRA.
Commission agents and brokers are named service providers in the provincial schedules. In Punjab the PRA taxes commission agent services on the gross commission, and registration there does not wait for a turnover figure. The standard rate has been 16 per cent. Rates and schedules change, so check the current entry with your own authority before you print a bill.
So your commission bill is not an FBR digital invoice at all. It follows your province's system. If you send a commission bill through FBR's Digital Invoicing API, it will be wrong even if it goes through.
'FBR vs Provincial (SRB/PRA/KPRA) E-Invoicing: Which System Do Service Businesses Report To? (2026)' sets out which authority takes which bill, and what happens to a business that reports to both.
What an arhti actually has to do
Work through these in order. Most mandi businesses stop at step two, and that is fine if the answer is honestly no.
One. Decide what you really sell. Pure commission work on exempt produce is a very different tax position from buying and reselling stock in your own name. Write down which of the two each deal was.
Two. Check whether you are registered for sales tax with FBR, and whether FBR has notified you to integrate. If you are not registered and not notified, digital invoicing does not start for you yet. Keep your records anyway.
Three. Register with your provincial authority for the commission. This is the step people skip. The commission is taxable in most provinces even when the goods themselves are exempt.
Four. If you are registered and notified with FBR, post every goods sale as a digital invoice, exempt ones included, under scenario SN006.
Five. Keep the two invoice books apart. Provincial commission bills in one file, FBR digital invoices in another. An officer from either side will ask for only his own.
Six. Keep everything for six years. That is how long sales tax records must be held in Pakistan. It matters more in a mandi, where there are many small deals and few written contracts.
Digi Invoice posts goods invoices to FBR and stores the IRN against each one. Exempt sales are handled as a normal case, not a workaround. Create your free account, post a test invoice in the sandbox first, then switch to live.
Four mistakes that cost mandi businesses money
Putting the commission on the FBR invoice. The goods sale and your cut are two different bills for two different authorities. Adding your commission as a line on an FBR invoice mixes a provincial service into a federal goods return.
Thinking exempt means nothing to file. Exempt sets the tax at zero. It does not remove the invoice, the record or the return.
Ignoring the province completely. Many arhtis have never heard from the PRA or the SRB and assume that means they are clear. Provincial authorities have been widening their reach over commission and brokerage, and unregistered years do not disappear.
No paper on who owned the goods. If nothing in your file shows the produce belonged to the grower, a tax officer may treat the whole sale as yours. Then the turnover is yours too. A simple signed mandi slip naming the grower, the quantity and the rate is worth keeping.
Difficult words in this guide
Arhti (commission agent) — a trader who sells someone else's produce in a mandi and charges a commission instead of buying the goods himself.
Kacha arhat and pakka arhat — kacha arhat is pure commission work on goods you never own. Pakka arhat is buying the crop yourself and reselling it.
Exempt supply — a sale the law charges no sales tax on. It still has to be invoiced and recorded.
Sixth Schedule — the list inside the Sales Tax Act 1990 naming goods that are exempt, including fresh fruit, vegetables, eggs and unprocessed grain.
IRN (Invoice Reference Number) — the unique number FBR gives a digital invoice once it accepts it. Without it the invoice is not valid.
SN006 — FBR's scenario code for an exempt goods sale. It tells the system to expect a nil tax amount.