FBR Draft SRO 2099: Customs Agent Licence Exam in Pakistan Limited to Three Attempts, No-Shows Count
FBR draft SRO 2099 of 10 November 2026 caps the customs agent licence exam at three attempts. A no-show counts, and provisional licences end after the third.
Short answer: FBR wants to cap the customs agent licence exam at three attempts for every applicant. Under draft S.R.O. 2099(I)/2026, dated 10 November 2026, skipping an exam after applying counts as an attempt, just like failing it. A provisional licence holder who does not pass within three attempts would lose the licence.
The Federal Board of Revenue (FBR) published the draft on 10 November 2026 on its customs SRO list. It changes rule 93 of the Customs Rules, 2001, the rule that sets the qualification test for a customs agent, also called a clearing agent. We downloaded the signed notification and read it against the current rule from December 2024.
Draft S.R.O. 2099 sets a limit of three attempts
The draft replaces sub-rule (2) of rule 93 with one paragraph. Every applicant, including a provisional licence holder, gets "a maximum of three attempts to qualify the examination". That is the core change.
The draft then defines an attempt. Not appearing for the exam after applying counts as one attempt. Appearing and not qualifying also counts as one attempt. So an applicant cannot keep a place in the queue by registering and staying away.
For provisional licence holders, the draft adds a clear end point. A holder who fails to appear, or fails to qualify, within three attempts has the provisional licence cancelled. That happens after the third attempt, or after not appearing in the three consecutive exams held after 24 December 2024.
| Point | Rule 93 now (S.R.O. 2071 of 2024) | Draft S.R.O. 2099 of 2026 |
|---|---|---|
| Who is limited | Existing provisional licence holders | Every applicant, including provisional holders |
| Number of chances | Two, then blocked, with a last third chance | A maximum of three attempts |
| Skipping the exam | Provisional holders who miss the first exam lose the licence | Counts as one attempt for everyone |
| End for provisional holders | Blocked after the second failure | Cancelled after the third attempt, or after missing three exams in a row held after 24 December 2024 |
| Pass mark | At least 50% in the written exam | Not changed by the draft |
The current rule dates from December 2024
FBR rewrote the licensing rules for customs agents in S.R.O. 2071(I)/2024, dated 24 December 2024. That notification created a yearly cycle. FBR invites applications each year on 1 November, an accredited institution runs a written test, and an applicant needs at least 50% to be considered.
The 2024 text gave existing provisional licence holders two chances. After a second failure the provisional licence would be blocked, with a last third chance. It did not say clearly whether a no-show counted, and it spoke only of provisional holders, not every new applicant. The draft closes both gaps.
Our full guide to getting and renewing a customs agent licence covers the application, the Rs 10,000 yearly renewal fee and the test syllabus.
Who the change affects
The draft matters most to three groups. Each should plan for the limit now, because a missed exam would use up one of only three chances.
- Provisional licence holders: people already clearing goods on a provisional licence who have not yet passed the test. The draft counts their exams from 24 December 2024, so some may already have used one or two attempts.
- New applicants: anyone applying in the yearly 1 November cycle. Registering and then skipping the exam would cost an attempt.
- Clearing firms: agencies whose staff or partners hold provisional licences. A cancelled licence would stop that person filing goods declarations.
The draft does not say what happens to a regular, full licence holder. It speaks only of applicants and provisional licence holders.
How to send an objection before it becomes final
This is a draft under sub-section (3A) of section 219 of the Customs Act, 1969. FBR must consider objections and suggestions sent within seven days of the draft's publication in the official Gazette. After that, FBR can notify a final version, with or without changes.
- Read the draft S.R.O. 2099(I)/2026 on FBR's SRO page under Customs.
- Write your objection or suggestion, naming rule 93(2) and the draft number.
- Send it to FBR's Secretary (Law and Procedure), Customs, who signed the draft.
- Send it quickly. The seven days run from the Gazette date, which we could not confirm.
- Watch FBR's SRO list for the final notification.
Trade bodies and customs agents' associations often file joint comments. If you belong to one, ask whether it is responding. For how to tell a real FBR notification from a fake one, use our guide to checking an FBR SRO.
A second customs agent draft in one week
This is FBR's second draft on customs agent licensing in November. On 3 November it published draft S.R.O. 2088(I)/2026, which would send licence renewals through a committee that checks each agent's past record. We covered it in our report on the licence renewal committee draft.
Together the two drafts point one way. Getting a licence would need a pass within three tries, and keeping it would depend on past performance. Both are still drafts as of 10 November 2026.
Common questions
Is the three-attempt limit already in force?
No. S.R.O. 2099(I)/2026 is a draft dated 10 November 2026. It takes effect only when FBR notifies a final version.
Does missing the exam count as an attempt?
Yes, under the draft. Not appearing after applying counts as one attempt, the same as failing.
What happens to a provisional licence after three attempts?
The draft says it is cancelled after the third attempt, or after missing three consecutive exams held after 24 December 2024.
What is the pass mark for the customs agent exam?
At least 50% in the written exam, under rule 93 as set in December 2024. The draft does not change it.
How long do I have to object?
Seven days from the draft's publication in the official Gazette. We could not find the Gazette date, so send comments as soon as possible.
Does this apply to full licence holders?
The draft names applicants and provisional licence holders only. It does not mention holders of a full licence.
Last checked: 10 November 2026, from draft S.R.O. 2099(I)/2026 and S.R.O. 2071(I)/2024 on FBR's SRO list. See also the list of every customs SRO of 2026.
About the author
Tax, Bills and Technology Writer
Ali Akhtar is a young and curious voice here at Pakistan Era. He is currently pursuing his A-Levels and has a growing interest in Pakistan’s changing industrial landscape and educational trends. Ali likes to write in a way that helps him explain and explore the world around him. His writing reflects the perspective of the new generation navigating the evolving trends of Pakistan where technology, youth innovation, and shifting opportunities are reshaping the country’s future.
