SRO 1852(I)/2025 Explained: FBR Digital Invoicing Deadlines, the PDF, and Who It Covers

SRO 1852(I)/2025 is the FBR order dated 24 September 2025 that fixed the last set of start dates for FBR Digital Invoicing. It took the place of two earlier orders, and the final group had to be live by 31 December 2025.

Below we explain what the order says and what an SRO actually is. We also show where the PDF really sits on FBR's website, and what to do if your business is still not live.

If you only want the document, here is the direct link on FBR's own server, checked live on 17 September 2026: download1.fbr.gov.pk/SROs/2025924149054920SRO1852.pdf. It is a PDF of about 340 KB, dated 24 September 2025. Save it. Do not pay anyone for a copy of a free government notification.

SRO 1852(I)/2025 is a notification — a written order the government publishes — issued by the Federal Board of Revenue on 24 September 2025. It set a fresh timetable for FBR Digital Invoicing, the system in which every sales tax invoice is sent to FBR over the internet and stamped before you hand it to the buyer.

It supersedes two earlier orders. Supersedes means it takes their place completely. Those two were SRO 709(I)/2025 of 22 April 2025 and SRO 1413(I)/2025 of August 2025. So if an old article shows you a date from either of them, that date is dead. SRO 709(I)/2025: FBR Digital Invoicing Integration Rules Explained and SRO 1413(I)/2025: FBR's First Phased E-Invoicing Deadlines (and What Replaced Them) show what changed.

The order splits registered persons into groups by size and by the kind of business they run. Each group got three dates: a date to register on the portal, a date to finish testing, and a date to start issuing real digital invoices. The last group's date was 31 December 2025. Nobody registered for sales tax was left out. The groups only decided when you started, never whether you had to start at all.

SRO is short for Statutory Regulatory Order. It is a written order that a body like FBR is allowed by law to issue on its own, without going back to Parliament. Think of the tax law as the rule book, and an SRO as a signed note from the referee that changes a date or adds a detail inside that rule book.

Every SRO carries a number and a year, written like 1852(I)/2025. The (I) only marks which part of the Gazette — the government's own newspaper of record — it was printed in. A newer SRO can supersede an older one, which is why digital invoicing has already passed through SRO 709, then SRO 1413, and now SRO 1852.

The law underneath all three never changed. That law is Rule 150Q of the Sales Tax Rules 2006, which says notified registered persons must connect to FBR's computerised system through PRAL or a licensed integrator. Rule 150Q of the Sales Tax Rules: The Legal Basis for FBR Digital Invoicing (2026) explains it. Put simply, the rule is the duty, and the SRO is only the timetable.

Thousands of people search for this PDF and give up. Here is the reason, checked on 15 September 2026. FBR's own Digital Invoicing Legal Provisions page, at fbr.gov.pk/di-legal-provisions/173967/173968, still lists only three documents. Those are the Digital Invoicing Rules in SRO 69(I)/2025, the SRO 709(I)/2025 PDF of 22 April 2025, and a one-page extension letter of 20 June 2025. That letter moved corporate persons to 1 July 2025 and non-corporate persons to 1 August 2025. SRO 1852(I)/2025 is not on that page at all.

So do not hunt on the digital invoicing page. The file itself is at download1.fbr.gov.pk/SROs/2025924149054920SRO1852.pdf. If that link ever moves, use FBR's main notification search at fbr.gov.pk/sros and look up the number 1852 with the year 2025. It is still worth saving the SRO 709 PDF that the legal provisions page does carry, because SRO 1852 changes the dates in that schedule rather than the duties inside it.

One warning. A plain web search for the number 1852 also pulls up FBR property valuation tables from 2022 and 2024, where 1852 is only a row number in a long list. Before you trust a file, check that it says S.R.O. 1852(I)/2025 and carries the date 24 September 2025.

Every date in SRO 1852(I)/2025 has now passed. There is no waiting period left. If you are registered for sales tax and still writing bills by hand, or printing them from an offline program, you are late rather than early.

The steps are the same for everyone. Register for digital invoicing inside IRIS. Choose PRAL or a licensed integrator. Pass the sandbox test — sandbox is FBR's free practice system, where test invoices do not count as real ones. Collect your production token, which is the password-like key that lets your software post real invoices. Then send every invoice through and print the IRN (Invoice Reference Number — the unique number FBR gives each invoice) and the QR code on the face of it. How to Register for FBR Digital Invoicing (2026): Step by Step on IRIS and FBR Digital Invoicing Compliance Checklist (2026): Everything You Need Before Go-Live take you through it.

Being late now costs money. FBR Sales Tax Circular 01 of 2026 Explained: Invoices for Exempt Sales and Advances, Rs 1 Million Non-Integration Penalty, Simulated Invoice Register and the 20% Input Tax Penalty gives the current non-integration penalty, and FBR E-Invoicing Enforcement 2026: Notices, Audits and Compliance covers the wider list of fines. If you think you may be outside the net altogether, read Who Is Exempt from FBR Digital Invoicing? Cottage Industry, Unregistered Sellers & Services (2026) before you assume anything.

Digi Invoice handles the technical half for you — guided FBR setup, sandbox and production posting, checking against FBR's DI v1.12 rules, and the IRN and QR printed on every invoice — so a business notified under SRO 1852(I)/2025 can get compliant without building any integration of its own.

SRO (Statutory Regulatory Order) — a written order FBR can issue on its own under the tax law, usually to set or move a date.

Supersede — to completely replace something older, so the older version no longer applies.

Gazette — the government's official newspaper of record, where every SRO is printed.

Notified — officially named in an order, so the duty now applies to you.

Production token — the password-like key from FBR that lets your software post real invoices instead of test ones.