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Retailers and shopkeepersLaw current to 30 June 2026

Does taking card payments or having a 1,000 square foot shop still make me a Tier-1 retailer?

Short answer

No, not on their own. The Finance Act, 2026 omitted sub-clauses (f) and (g) of section 2(43A) of the Sales Tax Act, and the Finance Act, 2023 omitted the shop-area limb (e). As amended to 30 June 2026, neither a card machine nor floor area is a Tier-1 test. The remaining limbs still apply.

Applies to: Shopkeepers who accept debit or credit cards, or whose shops are 1,000 square feet or larger, and who were told this made them Tier-1 retailers.

Neither test survives in the law as amended to 30 June 2026. Having a bank card terminal, or a shop of 1,000 square feet or more, used to be enough to make a retailer Tier-1 under section 2(43A) of the Sales Tax Act, 1990. Both limbs have been omitted, the floor-area test in 2023 and the card-machine test in 2026.

What does the law say?

Section 2(43A) defines a Tier-1 retailer as a retailer “falling in any one or more of the following categories”. The list has changed several times. Here is what happened to the tests people most often ask about:

Old limb What it covered (in plain words) What happened
(e) A retailer whose shop measured 1,000 square feet or more, or 2,000 square feet or more for a furniture retailer Omitted by section 5 of the Finance Act, 2023
(ga) Jewellery sellers, excluding shops of 300 square feet or less Omitted by section 5 of the Finance Act, 2023
(f) A retailer who acquired a point of sale for accepting debit or credit card payments from a bank or a digital payment provider authorised by the State Bank of Pakistan Omitted by section 4 of the Finance Act, 2026
(g) A retailer whose deductible advance income tax on purchases from suppliers over twelve months exceeded a threshold notified by the Board Omitted by section 4 of the Finance Act, 2026

Section 4 of the Finance Act, 2026 is short on this point: in clause (43A), “sub-clauses (f) and (g) shall be omitted”. Section 1 of that Act brings it into force on 1 July 2026, unless otherwise provided. The consolidated Sales Tax Act to 30 June 2026 prints those sub-clauses as omitted, with footnotes naming the Finance Act, 2026.

What still makes a shop Tier-1?

After these changes, section 2(43A) keeps these limbs:

  1. (a) a unit of a national or international chain of stores;
  2. (b) a shop in an air-conditioned shopping mall, plaza or centre, excluding kiosks;
  3. (c) cumulative electricity bills above Rs. 1,200,000 in the immediately preceding twelve consecutive months;
  4. (d) a wholesaler-cum-retailer with turnover of more than Rs. 200 million engaged in bulk import and supply of consumer goods to retailers and to the general public;
  5. (gb) turnover above Rs. 200 million in the immediately preceding twelve consecutive months, declared or worked back from advance income tax that suppliers collect under the Income Tax Ordinance;
  6. (h) any person or class prescribed by the Board, with a new proviso letting the Board also exclude persons by notification.

The withholding-tax idea in old limb (g) did not vanish completely. The new limb (gb) uses the same supplier deductions, but only as a way of working back turnover against a fixed Rs. 200 million figure, rather than a Board-notified threshold.

Worked example (illustrative figures)

Nadia runs a 1,200 square foot ladies’ clothing shop on a street in Saddar, Karachi. It is not in a mall, not part of a chain, and it has a card machine from her bank. Her made-up figures: electricity bills of Rs. 480,000 for the last twelve months and turnover of Rs. 28 million.

Test Nadia’s facts Met?
Chain store (a) Single independent shop No
Air-conditioned mall or plaza (b) Street-level shop No
Electricity above Rs. 1,200,000 (c) Rs. 480,000 No
Turnover above Rs. 200 million (d) or (gb) Rs. 28 million No
Board notification (h) None assumed No
Card machine Has one Not a test since 1 July 2026
Floor area 1,000 sq ft 1,200 sq ft Not a test since the Finance Act, 2023

On these facts, no current limb applies. If Nadia moved the same shop into an air-conditioned plaza, limb (b) would apply regardless of the card machine or the floor area.

What if …?

What if my shop is in a mall and I take cards? You are Tier-1 because of the mall, under limb (b). The card machine is irrelevant to that result.

What if I was registered and integrated because of the card machine? The Act as amended does not contain a transitional provision for retailers who were Tier-1 only under old limb (f). It does not say whether an existing Tier-1 status, registration or integration ends automatically. The law is silent, so this page does not resolve it.

What if the Board names card-accepting retailers again? Limb (h) lets the Board prescribe any other person or class of persons as Tier-1. Any such notification is outside this corpus.

Common mistakes

  • Relying on guidance written before July 2026. Many explanations still list the card-machine test. It was omitted by the Finance Act, 2026.
  • Measuring the shop. Floor area has not been a Tier-1 test since the Finance Act, 2023.
  • Assuming “not Tier-1” means “no sales tax”. A retailer outside Tier-1 is generally charged sales tax through the monthly electricity bill under section 3(9).
  • Forgetting integration for those who remain Tier-1. The proviso to section 23(6) still requires all Tier-1 retailers to integrate their outlets with the Board’s computerized system from the date and in the manner the Board prescribes.

What to check in the official text

Compare clause (43A) of section 2 in the Sales Tax Act as amended to 30 June 2026 with section 4 of the Finance Act, 2026 and section 5 of the Finance Act, 2023. Then check whether the Board has issued any notification under limb (h) that prescribes or excludes your class of retailer.

Where this comes from in the law

  1. Finance Act, 2026, section 4 (Amendments of the Sales Tax Act, 1990 (VII of 1990))

    (ii) sub-clauses (f) and (g) shall be omitted;

    As amended to 2026. Download official PDF

  2. Finance Act, 2026, section 1 (Short title and commencement)

    It shall, unless otherwise provided, come into force on the first day of July, 2026.

    As amended to 2026. Download official PDF

  3. Finance Act, 2023, section 5 (Amendments of the Sales Tax Act, 1990)

    (c) in clause (43A), sub-clauses (e) and (ga) shall be omitted;

    As amended to 2023. Download official PDF

  4. Sales Tax Act, 1990, section 2 (Definitions)

    (a) a retailer operating as a unit of a national or international chain of stores;

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

  5. Sales Tax Act, 1990, section 3 (Scope of tax)

    tax shall be charged from retailers, other than those falling in Tier-1, through their monthly electricity bills

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

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

    all Tier-1 retailers shall integrate their retail outlets with Board’s computerized system for real-time reporting of sales.

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

Related questions people ask

When did the card machine test stop applying?
Section 4 of the Finance Act, 2026 omitted sub-clauses (f) and (g) of section 2(43A), and section 1 of that Act brings it into force on 1 July 2026 unless otherwise provided. The Sales Tax Act as amended to 30 June 2026 shows both sub-clauses as omitted.
My shop is 1,500 square feet. Is it Tier-1?
Not because of its size. The floor-area limb, sub-clause (e), was omitted by the Finance Act, 2023. The shop can still be Tier-1 under another limb, such as being in an air-conditioned mall or plaza, or having turnover above Rs. 200 million.
If I was Tier-1 only because of my card machine, what happens now?
On the current wording, a card machine no longer places a shop in Tier-1. The Act does not contain a transitional rule for retailers who were Tier-1 only under the omitted sub-clause (f), so it does not say how an existing registration or integration is treated.

Last reviewed 2026-09-25

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