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Retailers and shopkeepersLaw current to 30 June 2026

What is the penalty for issuing a receipt without a valid FBR invoice number or QR code?

Short answer

Serial 24 of the section 33 table in the Sales Tax Act, 1990 sets a penalty of Rs. 500,000 or 200% of the tax involved, whichever is higher, for an integrated person who issues an invoice without the prescribed invoice number or QR code. The premises can be sealed, and a Special Judge can order up to two years' imprisonment.

Applies to: Tier-1 retailers and other registered persons already integrated with FBR's computerized system for real-time reporting of sales.

What does the law say?

Serial 24 of the table under section 33 of the Sales Tax Act, 1990 deals with a person who is integrated with the Board’s computerized system for reporting sales and who does any of these:

  • conducts transactions in a way that avoids monitoring, tracking, reporting or recording;
  • issues an invoice that does not carry the prescribed invoice number, barcode or QR code;
  • issues an invoice bearing a duplicate invoice number or a counterfeit barcode or QR code;
  • defaces the prescribed invoice number, barcode or QR code.

The penalty column provides three separate consequences:

Consequence What serial 24 says
Money penalty Rs. 500,000 or 200% of the amount of tax involved, whichever is higher
Prosecution On conviction by a Special Judge, simple imprisonment up to two years, or an additional fine up to Rs. 2 million, or both
Sealing The business premises “shall be liable to be sealed” by an officer of Inland Revenue in the manner prescribed

A person who abets the offence is liable, on conviction by a Special Judge, to simple imprisonment of up to one year, or a fine of up to Rs. 200,000, or both.

What counts as a valid receipt?

Section 23(1), as amended by the Finance Act, 2026, requires a registered person to issue a tax invoice “bearing a verifiable and unique FBR invoice number”. A proviso says this condition applies from the time the Board notifies.

For integrated persons, rule 150R(13) of the Sales Tax Rules, 2006 lists the particulars of an electronic invoice, including a unique FBR invoice number, a unique and verifiable QR code, the POS software registration number and the FBR digital invoicing logo. Rule 150R(3) adds that no supply shall be made except through integrated outlets or POS machines. A handwritten slip or a receipt from a machine that is not integrated will not carry these particulars.

How are unverified invoices detected?

Rule 150ZEO lists where the information can come from:

  1. Tax Asaan or the POS Dashboard. A customer or official checks the invoice and it shows as unverified.
  2. Mystery shopping. Section 56C(2) lets the Board prescribe mystery shopping of invoices from integrated Tier-1 retailers. Under rule 150ZEM, a person or firm authorized by the Board buys from Tier-1 retailers at random, verifies the invoices on FBR’s online system, and reports fake or invalid invoices to the Board.
  3. Any other reliable source.

Before declaring an invoice unverified, the Commissioner “shall verify any invoice through invoice number or QR code”. If there is evidence of unverified invoices, the Commissioner seeks the Chief Commissioner’s written approval to seal.

Worked example (illustrative figures)

Two integrated Tier-1 retailers in Lahore are caught issuing receipts that do not verify. All amounts of tax are invented.

Retailer A: one receipt, tax involved Rs. 12,000.

  • 200% of Rs. 12,000 = Rs. 24,000
  • Compare with Rs. 500,000: the higher is Rs. 500,000
  • Penalty: Rs. 500,000

Retailer B: a software audit shows a batch of unverified sales, tax involved Rs. 900,000.

  • 200% of Rs. 900,000 = Rs. 1,800,000
  • Compare with Rs. 500,000: the higher is Rs. 1,800,000
  • Penalty: Rs. 1,800,000

The break-even point is tax involved of Rs. 250,000, since 200% of Rs. 250,000 is Rs. 500,000. Above that, the percentage figure is the larger one.

In both cases sealing and prosecution are separate possibilities. The Act does not define how “tax involved” is measured, for example per invoice or per batch.

What happens after the shop is sealed?

Under the de-sealing rule for integrated retailers in Chapter XIV-AD of the Rules, the Commissioner imposes the serial 24 penalty by order. De-sealing is due within 24 hours of payment of the penalty and the audit demand, once the software bug is removed. A software audit of all POS machines in all branches follows within three working days, and any under-declared sales found create a demand for the tax evaded. The registered person may appeal the order.

Common mistakes

  • Thinking the penalty is 200% only. Serial 24 takes whichever is higher, so Rs. 500,000 is the floor.
  • Treating a defaced QR code as harmless. Defacing the prescribed invoice number, barcode or QR code is itself listed in serial 24.
  • Assuming only the owner is exposed. Abetting the offence carries its own punishment.
  • Selling through a non-integrated counter. Rule 150R(3) bars supplies other than through integrated POS machines.

What to check in the official text

Read serial 24 in the section 33 table of the Sales Tax Act, 1990 as amended to 30 June 2026, and the Board notification bringing the new section 23(1) invoice-number condition into force, which is not held on this site. In the Sales Tax Rules, 2006 (amended to 30 June 2025), read rules 150R, 150ZEM and 150ZEO. The de-sealing rule for integrated retailers is embedded in the text of our copy rather than set as a heading, so check it in the official PDF.

Where this comes from in the law

  1. Sales Tax Act, 1990, Section 33, Table, S. No. 24

    As amended to 2026-06-30. Download official PDF

  2. Sales Tax Rules, 2006, section 150ZEO (Procedure for sealing of business premises of integrated tier-1 retailers)

    reported as unverified on “Tax Asaan” application or POS Dashboard;

    As amended to 2025-06-30. Download official PDF

  3. Sales Tax Rules, 2006, section 150ZEM (Procedure for mystery shopping)

    shall verify the invoices from the online system of FBR and in case of fake or invalid invoice, report the matter to the Board for necessary action as per relevant provisions of the Act and the rules thereunder.

    As amended to 2025-06-30. Download official PDF

  4. Sales Tax Rules, 2006, section 150R (Obligations and requirements)

    No supply shall be made by the integrated person, except through the integrated outlets, point of sale or electronic invoice issuing machines.

    As amended to 2025-06-30. Download official PDF

  5. Sales Tax Act, 1990, section 56C (Prize schemes to promote tax culture)

    The Board may prescribe procedure for “mystery shopping” in respect of invoices issued by tier-1 retailers integrated with FBR online system randomly

    As amended to 2026-06-30. Download official PDF

  6. Sales Tax Act, 1990, section 23 (Tax Invoices)

    bearing a verifiable and unique FBR invoice number

    As amended to 2026-06-30. Download official PDF

Related questions people ask

Is the penalty Rs. 500,000 even for one small receipt?
Serial 24 sets Rs. 500,000 or 200% of the tax involved, whichever is higher. Where the tax on the receipt is small, 200% of it will be below Rs. 500,000, so the Rs. 500,000 figure applies. The entry does not scale the minimum down for small amounts.
Who can be sent to prison under serial 24?
The offender can, on conviction by a Special Judge, face simple imprisonment of up to two years, an additional fine of up to Rs. 2 million, or both. A person who abets the offence faces up to one year, a fine of up to Rs. 200,000, or both.
How does FBR find out about an unverified receipt?
Rule 150ZEO lists three routes: a report of an unverified invoice on the Tax Asaan application or POS Dashboard, invoices found physically or through mystery shopping, and any other reliable source.

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Last reviewed 2026-09-25

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