The Federal Board of Revenue (FBR) has introduced a facility allowing individuals who submit their income tax returns after the prescribed deadline to join the Active Taxpayers’ List (ATL) without paying the existing Rs25,000 surcharge. The facility has been introduced through Form ATL-U under SRO 2097(I)/2026, issued on November 10, 2026. Under the revised procedure, eligible late filers can secure inclusion in the ATL by submitting an undertaking through the FBR’s IRIS online tax system. However, the facility comes with a specific condition restricting property acquisitions for six months from the date the undertaking is successfully submitted. The amendment establishes an alternative route for taxpayers seeking ATL inclusion after missing the applicable filing deadline, while introducing a commitment related to property ownership during the specified period.
According to the notification, individuals who file their income tax returns for the latest tax year after the original due date or any officially extended deadline must furnish an undertaking through IRIS using the newly introduced ATL-U form. By submitting the form, the taxpayer formally commits not to purchase, acquire or otherwise obtain ownership or beneficial interest in any property for six months. This restriction applies from the date on which the undertaking is successfully furnished through the electronic system. The arrangement therefore allows late filers to access the ATL without paying the Rs25,000 surcharge, provided they agree to comply with the property-related condition. The undertaking is intended to establish a formal commitment from taxpayers who benefit from the revised inclusion mechanism, making compliance with the six-month restriction an essential requirement of the facility.
The FBR has also amended the Income Tax Rules, 2002, to incorporate the new procedure into the existing regulatory framework. The changes involve the insertion of additional sub-rules in Rule 81B and the inclusion of Form ATL-U in the First Schedule of the rules. The latest SRO follows amendments previously published through SRO 1691(I)/2026 on October 6, 2026. The November 10 notification provides the updated regulatory framework for implementing the facility and specifies the requirements that late filers must fulfil when seeking inclusion in the ATL without paying the surcharge. The use of IRIS as the submission channel also establishes an electronic record of the undertaking, allowing the tax authority to identify when the six-month restriction begins and monitor compliance with the conditions attached to the facility.
The six-month restriction period will begin from the date recorded on the electronic acknowledgement generated by IRIS after successful submission of Form ATL-U. This means that the relevant starting date will be determined by the system-generated acknowledgement rather than the date on which a taxpayer prepares the form or initiates the submission process. The FBR has also retained the authority to monitor whether individuals comply with the undertaking during the restricted period. According to the notification, the tax authority may examine information available under the Income Tax Ordinance, 2001, as well as information obtained from other government authorities, agencies, registries, financial institutions and any other lawful sources. This monitoring arrangement gives the FBR access to relevant information for checking property-related transactions and determining whether a taxpayer has breached the conditions under which the surcharge exemption was granted.
The notification further outlines the consequences for individuals who fail to comply with the undertaking. If the FBR establishes that a taxpayer has purchased, acquired or obtained ownership or beneficial interest in property during the six-month restriction period, the benefit provided under the facility will be withdrawn from the date of the breach. However, the taxpayer must first be provided with an electronic opportunity to present their position and respond to the identified violation. Once a breach is established following this opportunity to be heard, the individual’s inclusion in the Active Taxpayers’ List will be governed by the existing rules. This means that the exemption from the Rs25,000 surcharge will no longer remain available to the taxpayer from the date the violation occurs, and the normal ATL inclusion requirements will apply.
The revised mechanism provides late tax filers with an alternative to the surcharge-based route for joining the Active Taxpayers’ List, while placing a time-bound restriction on property acquisitions. For individuals who missed the filing deadline, the facility creates an option to obtain ATL inclusion by submitting the required undertaking rather than making the Rs25,000 payment. However, taxpayers considering this route must understand the six-month property restriction and the FBR’s authority to verify compliance through available financial, regulatory and government records. The amendments also strengthen the formal procedure by incorporating Form ATL-U into the Income Tax Rules, 2002, and establishing the electronic acknowledgement as the starting point for the restriction period.
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