ISLAMABAD: The Pakistan Medical Association (PMA) on Monday wrote a letter to the Federal Board of Revenue (FBR) claiming that tax on health services will further increase the burden on patients, expose their confidentiality and contribute to the brain drain.
It demanded immediate exclusion of all medical service providers, including doctors, dentists, physiotherapists, laboratories, diagnostic centres, private hospitals and medical care centres, from the scope of POS (point of sale)/electronic integration.
Moreover, the association suggested meaningful consultation with stakeholders prior to enforcement of any regulatory framework impacting essential health services.
The letter by PMA Secretary General Dr Abdul Ghafoor Shoro to the chairman FBR states that the inclusion of medical service providers within the ambit of mandatory POS/electronic invoicing integration as notified on Feb 18, 2026 is against the Constitution.
Inclusion of medical service providers in electronic invoicing integration is against Constitution, letter to FBR says
Medical consultation, hospitalisation and diagnostic services are not subject to sales tax under prevailing fiscal laws. “POS integration is fundamentally a sales tax enforcement and monitoring mechanism designed for taxable supplies. Extending this mechanism to non-taxable essential services is legally incongruent and without rational nexus”, he added.
The letter claimed that healthcare is an essential service directly linked with the fundamental right to life under Article 9 of the Constitution. “Any regulatory burden that increases operational cost, administrative hardship, or compliance pressure on healthcare establishments inevitably transfers financial burden to patients—particularly the underprivileged. Imposing additional compliance structures on essential health services indirectly restricts access to healthcare and is therefore constitutionally questionable,” it added.
The letter, copies of which have been sent to finance and health ministers, the secretary Revenue Division and parliamentary committees, claimed that the impugned notification selectively included medical professionals and healthcare institutions while excluding other professional service providers such as lawyers and certain other regulated professions.
“Professional services, by nature, are not commercial retail transactions. Singling out healthcare providers for POS integration while exempting similarly placed professional services constitutes discriminatory classification without reasonable justification, offending Article 25 of the Constitution.
Healthcare services inherently involve sensitive personal and medical information. Mandatory real-time electronic integration with centralised systems raises serious concerns regarding confidentiality, privacy, and data protection. Medical records are protected under ethical codes, statutory regulations, and internationally recognised principles of medical confidentiality,” it stated.
Moreover, it claimed that medical practitioners and hospitals were already regulated under Provincial Healthcare Commission laws, Pakistan Medical and Dental Council framework and the Income Tax Ordinance compliance regime.
“Introducing an additional POS based enforcement framework results in regulatory duplication without demonstrable fiscal necessity. Increased compliance costs will inevitably translate into increased consultation fees, diagnostic charges and hospitalisation expenses.
This will disproportionately affect low-income patients, rural populations, chronic disease patients, and emergency care recipients. Such consequences run counter to the State’s obligation to ensure equitable access to healthcare,” it stated.
While talking to Dawn, Dr Shoro said that while public sector health facilities were providing treatment to only 30 per cent patients, 70pc patients go to private sector to get medical treatment.
“We are not talking about large hospitals and medical consultants who charge Rs5,000 fee for each visit. PMA is concerned about doctors who sit at small clinics and charge Rs300 to Rs400 from patients. Now they will also be forced to pay tax on that Rs300. It will not only discourage doctors but will also burden the patients,” he explained.
Dr Shoro said the notification of FBR will hurt the poor more. “I personally know a cardiologist who had come to Pakistan to serve the poor but now he has decided to return to United Kingdom,” he said.
He said that in the past there was no tax on services but now health fraternity has been singled out and tax has been imposed on it.
He claimed that POS systems were designed primarily for monitoring retail supply chains and commercial enterprises.
“Medical consultation is a professional service governed by ethics and fiduciary duty, not a retail supply transaction. The inclusion of healthcare establishments under the same compliance regime lacks rational classification,” Dr Shoro said.
Published in Dawn, February 24th, 2026
