GST LUT Filing Online: Complete Guide to Form RFD-11 Under Rule 96A (FY 2026-27)
Filing a GST LUT means submitting Form GST RFD-11 online on the GST portal once
a year, which lets you export goods or services and supply to SEZ units without paying IGST
upfront on every invoice. For IT exporters, SaaS companies, freelancers billing overseas
clients, and goods exporters, this single filing is what keeps working capital out of a refund
queue for an entire financial year.
This guide walks through the exact screen-by-screen process on www.gst.gov.in, who qualifies,
what the three self-declarations commit you to, the foreign remittance deadlines that actually
get enforced, and what happens if you skip LUT filing altogether.
Validity
1 Financial Year (Apr 1 to Mar 31)
Approval
Typically Instant
Key Takeaways
LUT is filed in Form GST RFD-11 under Rule 96A of the CGST Rules, 2017, and covers
exactly one financial year - April 1 to March 31.
Any GST-registered exporter qualifies unless they've been prosecuted for tax
evasion exceeding ₹2.5 crore under GST or earlier tax laws; that narrow group must
furnish a bond with bank guarantee instead.
Goods must leave India within 3 months of the invoice date; service payments must
come in as convertible foreign exchange within 1 year of the invoice date.
The form needs details of two independent witnesses and is signed with DSC
(mandatory for companies and LLPs) or EVC (for proprietorships and
partnerships).
A fresh LUT must be filed every year before the new financial year starts - last
year's approval doesn't carry forward.
What Form GST RFD-11 Actually Does
A Letter of Undertaking is your formal promise to the government that you'll complete the export
transaction and bring in foreign exchange within the prescribed window, in exchange for not
having to pay IGST on each invoice and then chase a refund afterward. Without an LUT, you have
two legal routes to export: pay IGST on every outward supply and file for a refund later through
GST refund claims under
RFD-01, or furnish a bond backed by a bank guarantee. For most exporters, LUT is simply the
faster and cheaper of the three paths, since it removes the step of parking tax money with the
government and waiting weeks or months to get it back.
The legal authority for all of this sits in Rule 96A of the CGST Rules, 2017, read with Section
16 of the IGST Act. Notification 37/2017-Central Tax opened LUT up to nearly every registered
exporter, removing an earlier, more restrictive condition that had tied eligibility to a minimum
foreign remittance or export turnover.
Who Should File a GST LUT
This process is built for anyone making a zero-rated supply under GST:
IT and software exporters billing clients abroad for development, consulting, or
managed services
SaaS companies collecting subscription revenue in foreign currency
Freelancers registered under GST and invoicing overseas clients directly
Goods exporters shipping physical merchandise out of India
SEZ suppliers making zero-rated supplies to Special Economic Zone units or
developers
If you haven't
registered for GST yet, LUT filing isn't available until your GSTIN is active - start with
new GST registration
first, since the LUT form pulls your legal name and registration details directly from that
record.
Eligibility: Who Can File, and the One Group That Can't
The eligibility bar is deliberately low. Under Rule 96A(1), any GST-registered person making
zero-rated supplies can file LUT, with a single disqualifying condition: anyone prosecuted for
an offence under the CGST Act, IGST Act, or any earlier tax law - Central Excise, Service Tax,
State VAT - where the tax evaded exceeds ₹2.5 crore is barred from using LUT and must furnish a
bond with bank guarantee instead.
For the overwhelming majority of exporters, software businesses, and freelancers reading this,
that disqualification simply doesn't apply. There's no minimum turnover requirement, no cap on
how many times you can file, and first-time exporters qualify in their very first year of GST
registration.
The Three Self-Declarations You're Signing
Form RFD-11 asks you to tick three checkboxes before you can submit. In plain terms, you're
committing to:
1
Export within three months
Export the goods or services within three months from the invoice date (or whatever
extended period a Commissioner has permitted for your case), without payment of
integrated tax
2
Follow the export conditions
Follow the export conditions laid down under GST law and the terms of the LUT throughout
the financial year
3
Pay IGST with interest on failure
Pay the IGST that would otherwise have applied, along with 18% annual interest under
Section 50, if you fail to export within the prescribed window - counted from the
invoice date to the date payment is actually made
These aren't boilerplate checkboxes to click through quickly. Rule 96A ties real financial
consequences to each one, which the breach section below covers in detail.
Step-by-Step: How to File LUT on the GST Portal
| Step |
Action |
Notes |
| 1 |
Log in at www.gst.gov.in with your GSTIN credentials
|
Use the production portal, not a sandbox or test environment
|
| 2 |
Go to Services → User Services → Furnish Letter of Undertaking (LUT)
|
This path doesn't change year to year |
| 3 |
Select the financial year from the dropdown (e.g., 2026-27)
|
Filing opens before the new financial year begins |
| 4 |
Upload last year's manually-filed LUT, if applicable
|
PDF or JPEG only, 2 MB maximum; not required if you filed online previously
|
| 5 |
Tick all three self-declaration checkboxes |
Required to proceed to the next screen |
| 6 |
Enter name, full address, and occupation for both witnesses
|
Witnesses must be individuals, not company entities
|
| 7 |
Enter the place of filing and the authorised signatory's name
|
Typically your principal place of business as per GST registration
|
| 8 |
Preview the form and check every field |
Any mismatch with your core registration details needs correction before filing,
not after
|
| 9 |
Sign and file with DSC or EVC |
DSC is mandatory for companies and LLPs; EVC (OTP-based) works for
proprietorships and partnerships
|
| 10 |
Download the ARN and acknowledgment |
Save both - the ARN is your proof of filing if any query comes up later
|
The Witness Requirement, Explained
Two independent witnesses are a fixed requirement on Form RFD-11 - their name, complete address
with PIN code, and occupation go into the form, though they don't sign anything on the portal
themselves. Most businesses filing repeatedly keep a standard pair of witnesses (often a company
employee and an accountant or consultant not directly involved in the transaction) ready in
advance, which turns this step from a scramble into something that takes under two minutes.
DSC vs. EVC: Which Applies to You
Companies and LLPs must sign with a registered Digital Signature Certificate - EVC isn't
accepted for these entity types. Proprietorships and partnerships can use EVC instead, where the
portal sends a one-time password to the authorised signatory's registered mobile number and
email, and entering that OTP completes the filing.
Downloading Your LUT Acknowledgment
Once filed, the GST portal generates an Application Reference Number immediately in most cases -
LUT filing is one of the few GST processes that's typically approved the moment you submit,
rather than going through a separate departmental review. The acknowledgment and ARN are
available for download from the same screen, and you'll want a copy on hand, since export
invoices should quote the LUT reference going forward.
Foreign Remittance Timelines You're Actually Bound By
This is the condition most service exporters underestimate, because the LUT itself is approved
instantly, but the obligations inside it run for months afterward.
| Supply |
Deadline |
Note |
| Goods |
Must physically leave India within 3 months of the export invoice date
|
The Commissioner can extend this in genuine cases, but that extension isn't
automatic - you have to request it.
|
| Services |
Payment must be realised in convertible foreign exchange (or in rupees, where
RBI specifically permits it) within 1 year of the invoice date under Rule
96A(1)(b)
|
Counted from the invoice date. |
Some
advisory sources note that where FEMA's own remittance window - currently 15 months per RBI
guidance - runs longer than the 1-year GST deadline, the later of the two dates may apply in
practice. Because RBI's FEMA timelines are revised periodically, confirm the current remittance
period directly through your bank's export documentation team or FEMA regulations in force at
the time of your transaction, rather than relying on any single figure quoted online.
What Happens If You Miss the Deadline
Missing either window doesn't void your GST registration or bar you from exporting again, but it
does trigger a direct cost: you become liable to pay the IGST that would have applied on that
specific invoice, plus 18% annual interest calculated from the invoice date to the date you
actually pay, with payment due within 15 days of the deadline lapsing. If export happens late or
payment comes in after the window closes, the benefit is restored for that transaction once
you've paid up - but the interest for the delay period still stands.
This is exactly why tracking invoice-wise realisation dates matters as much as the LUT filing
itself. An LUT that's filed correctly but never followed up with remittance tracking exposes you
to exactly the risk the filing was meant to avoid.
LUT Validity and Renewal for FY 2026-27
An LUT is valid for one financial year only - April 1 to March 31 - and does not roll over
automatically. You need a fresh RFD-11 filing before the new financial year begins if you want
uninterrupted zero-rated billing from April 1 onward. Filing early, rather than waiting until
the last week of March, avoids a gap where invoices raised without a live LUT technically
require IGST payment.
Renewal follows the identical process described above: log in, navigate to the same Furnish LUT
path, select the new financial year, complete the declarations and witness details again, and
sign. There's no shortcut or pre-filled carryover from the previous year's approval.
Export Under LUT vs. IGST Payment with Refund
| Factor |
Export Under LUT |
Export With IGST Payment + Refund |
| Upfront tax outflow |
None - invoice raised without IGST |
Full IGST paid on invoice value at time of supply |
| Working capital impact |
No capital blocked |
Capital locked until refund is processed |
| Paperwork per export |
Minimal, beyond the invoice itself |
Requires separate refund application in Form RFD-01 for each period
|
| Refund processing time |
Not applicable |
Typically several weeks to a few months, depending on scrutiny
|
| Annual compliance |
One LUT filing per financial year |
Refund claims filed on an ongoing basis as exports occur
|
| Best suited for |
Most regular exporters, SaaS businesses, freelancers with predictable export
volume
|
Exporters who prefer paying tax and claiming it back, or those temporarily
ineligible for LUT
|
| Interest risk |
Only if export/remittance deadlines are missed |
None, since tax is already paid |
For most IT exporters and freelancers with steady overseas billing, LUT is the practical default
- it keeps cash in the business rather than sitting with the government pending a refund cycle.
Businesses that do end up paying IGST on exports, whether by choice or because LUT isn't
available to them, should keep their
GSTR-1 and
GSTR-3B filings
accurate and current, since refund processing depends directly on how cleanly those returns
match the underlying export invoices.
Common Mistakes That Delay or Invalidate an LUT
| Mistake |
Why It Hurts |
|
Filing after the financial year has already started without checking invoice
dates.
|
Any invoice raised between April 1 and the date you actually file technically
falls outside LUT cover unless you've planned the timing carefully.
|
|
Listing a witness who's also a director or authorised signatory on the GSTIN.
|
Witnesses are meant to be independent of the transaction.
|
|
Not tracking the 3-month and 1-year deadlines invoice by invoice.
|
A missed single invoice doesn't cancel your LUT, but it does create an isolated
IGST-plus-interest liability for that transaction.
|
| Letting GST returns fall behind. |
Pending GSTR-1 or GSTR-3B filings and outstanding dues are a recurring reason
LUT applications get flagged for review rather than sailing through instantly.
|
| Forgetting to renew before April 1. |
The portal doesn't send an automatic reminder tied to your specific filing
history.
|
LegalDev India's GST LUT Filing Service
Our Tax & Foreign Trade Compliance Team - chartered accountants, company secretaries, and
GST consultants - has filed over 4,500 LUTs in Form RFD-11 for Indian exporters and service
providers, with a 100% instant approval record on the GST portal. We handle the full filing in
one sitting: witness documentation, the self-declarations, DSC or EVC signing, and the ARN
confirmation, so your export invoices stay IGST-free from day one of the financial year. If your
GSTR-1 or GSTR-3B filings have fallen behind and you're worried that could hold up your LUT
application, we clear that first before touching the RFD-11 form.
Get in touch before April 1 to have your FY 2026-27 LUT filed and your ARN in hand before your
first export invoice of the new year goes out.
Frequently Asked Questions
Got questions? Find clear answers from our CA / GST compliance team:
It's not mandatory in the sense that you must file one - you can instead pay IGST on
each export and claim a refund, or furnish a bond. But for anyone exporting
regularly, LUT is the only route that avoids both upfront tax outflow and
bond-related paperwork.
Filing is typically approved instantly on submission, since LUT doesn't require
departmental review the way some other GST applications do. The ARN and
acknowledgment are available for download immediately after signing.
Yes. Any GST-registered freelancer invoicing overseas clients for export of services
can file LUT in their own name, provided they aren't disqualified by the ₹2.5 crore
prosecution condition.
Yes. LUT validity runs exactly one financial year, April 1 to March 31, and has to
be refiled every year - there's no automatic renewal or carryover.
The process needs minimal documentation: your GST login credentials, witness details
for two individuals, and either a registered DSC or access to the authorised
signatory's registered mobile and email for EVC. Previous LUT copies are only needed
if you're uploading an old manually-filed version.
You can still export, but without a live LUT, each export invoice technically
attracts IGST at the applicable rate, which you'd then need to claim back through a
refund application rather than avoiding upfront.
For goods, the relevant deadline is export within 3 months of the invoice date, not
payment realisation - if that window is missed, IGST plus 18% interest applies,
payable within 15 days of the deadline lapsing.
Only for companies and LLPs. Proprietorships and partnerships can file using EVC,
which verifies identity through an OTP sent to the registered mobile and email
instead.
Yes, there's no rule against reusing the same witnesses across filings, as long as
their details - name, address, and occupation - are entered accurately each time.
LUT is a simple self-declaration with no financial backing required. A bond requires
a bank guarantee and applies specifically to the narrow group of exporters
disqualified from LUT due to prosecution for tax evasion above ₹2.5 crore.
Yes. Supplies to SEZ developers and units are treated as zero-rated supplies under
GST, and LUT covers them the same way it covers exports outside India.
Yes. There's no minimum operating history or turnover threshold attached to LUT
eligibility - a business can file LUT in the same financial year it receives GST
registration.
The GST portal doesn't offer a direct edit option for an already-filed LUT. In
practice, this typically means filing a fresh LUT application with corrected
details, though specific correction procedures should be confirmed with your
jurisdictional GST officer for your exact situation.
Yes, referencing your current LUT's ARN on export invoices is standard practice and
expected by most GST practitioners, since it ties each zero-rated invoice back to
the underlying authorisation.
No. LUT filing on the GST portal carries no government fee - it's a free
self-declaration process.
Every export invoice raised without a live LUT is treated as a supply with IGST
payable, meaning you'd need to pay IGST upfront on each one and then separately
apply for a refund, rather than exporting IGST-free from the outset.