Service brief · Chapter IV · Government registrations

File your GST LUT,export without the cash-flow drag.

A regular exporter renewing for the new financial year, a first-time exporter setting up post-GSTIN, or an SEZ supplier wanting to make zero-rated supplies without paying IGST upfront. Each of these needs the same Letter of Undertaking filed on the GST portal. The filing is free, quick, and saves months of working-capital drag.

Brief last revised · July 2026

I.
Part One

How the filing works

From the eligibility check to the LUT on the GST portal.

Why this brief exists

Situations that bring exporters to this filing

The Letter of Undertaking is one of the smallest GST filings by size and one of the most valuable by cash-flow impact. These are the four patterns behind almost every LUT application:

  1. i.

    Annual renewal, coming up on 1 April

    A regular exporter with LUT already filed for the current financial year. The new financial year is approaching (or has just started) and the LUT needs to be renewed for the new year. Filing before 1 April ensures no export interruption.

    Renew LUT for the new year
  2. ii.

    First-time exporter after GST registration

    A newly-GST-registered business is about to make its first export. Filing the LUT before the first export invoice is issued ensures the invoice is zero-rated under LUT rather than IGST-paid. Getting this right at the first invoice saves months of refund complexity.

    File LUT before first export
  3. iii.

    SEZ supplier making zero-rated supplies

    A DTA (Domestic Tariff Area) supplier making supplies to a SEZ unit. Section 16 of the IGST Act treats supplies to SEZ as zero-rated exports. An LUT lets the supplier deliver without IGST, which the SEZ buyer would otherwise have to claim as refund, a mutually-beneficial cash-flow saving.

    File LUT for SEZ supplies
  4. iv.

    Service exporter billing overseas clients

    An IT/ITeS business, consulting firm, or freelancer billing overseas clients in foreign currency. Service exports are zero-rated under Section 16 of the IGST Act. Without LUT, IGST would be charged on each invoice and refunded later; with LUT, the invoice is directly zero-rated. Cash-flow benefit is meaningful.

    File LUT for service exports
Who qualifies

Who can file an LUT

Rule 96A of the CGST Rules 2017 lets any registered taxpayer who intends to make zero-rated supplies file an LUT. The eligibility conditions are minimal.

  • GST registration is required

    The applicant must be a registered taxpayer under GST with an active GSTIN. Unregistered persons cannot file an LUT (and, generally, are not eligible to make export supplies at all).

  • No prosecution for tax evasion above ₹2.5 crore

    A taxpayer prosecuted for tax evasion (under GST or the earlier indirect tax laws) involving tax evasion exceeding ₹2.5 crore in the last 5 years cannot file an LUT. This is a narrow disqualification; the overwhelming majority of exporters qualify.

  • No specific turnover threshold

    Unlike some other schemes, LUT eligibility does not depend on turnover. Small exporters, medium-scale, and large enterprises all qualify equally.

  • Two witnesses required

    The LUT is filed with the details of two witnesses (name, address, occupation). Witnesses are typically employees, directors, or trusted acquaintances of the business. The witness function is nominal; no personal liability attaches to the witnesses.

The filing

What RFD-11 actually does

Form GST RFD-11 is the Letter of Undertaking that the exporter files with the GST authorities. It is a bond-like undertaking that the exporter will comply with export requirements, most importantly that the export proceeds will be realised within the time prescribed under FEMA (typically 9 months of shipment).

The LUT is filed entirely online on the GST portal (gst.gov.in) under Services > User Services > Furnish Letter of Undertaking. The exporter's details, GSTIN, and IEC are pre-filled from the GST profile. Two witnesses are added, the form is signed digitally, and submitted.

Approval is generally automated. Within 24-48 hours of submission, the LUT is acknowledged and available for download. The LUT is valid from the date of filing until 31 March of the current financial year, and needs to be renewed each year for continued zero-rated exports.

The outputs

  • FORM GST RFD-11
    The Letter of Undertaking. Filed online on the GST portal. Digitally signed by the authorised signatory. Valid until 31 March of the current financial year.
  • ARN (ACKNOWLEDGEMENT REFERENCE NUMBER)
    Issued at the time of submission. Used to track the status of the LUT and to reference it in subsequent GST returns.
  • LUT ACKNOWLEDGEMENT
    Downloadable from the portal within 24-48 hours of submission. This is the operative document to be retained for record and produced at the time of any refund claim or scrutiny.
From your side

Documents you will need to send

The list is short. The GST portal pre-fills most fields from the exporter's profile; only the LUT-specific details and witnesses have to be added.

About the business

  • GSTIN and PAN of the business (auto-pulled by the portal)
  • IEC number (needed for goods exports; also useful for services)
  • Address of the principal place of business (auto-pulled)
  • Class-3 DSC of the authorised signatory (usually the same DSC used for GST returns)

About the two witnesses

  • Full name of each witness
  • Complete address of each witness
  • Occupation of each witness (typically the job title within the business)
  • Aadhaar or PAN reference for each (optional in most cases but often asked for)
Step by step

Done within 2 to 3 working days

Most LUT filings wrap within a couple of days from the first engagement. The portal-side approval is largely automated; only the drafting and DSC-signing steps involve human action.

  1. Day 1

    Briefing and eligibility check

    You share the GSTIN, IEC, and details of the intended export activity. Eligibility under Rule 96A is confirmed: GST-registered exporter with no prosecution history for tax evasion above ₹2.5 crore in the last five years.

  2. Day 1

    LUT form drafting

    Form RFD-11 (LUT for the financial year) is drafted with the exporter's details, GSTIN, IEC, and PAN. Two witnesses are identified from among trusted acquaintances of the business (typically employees or fellow directors).

  3. Days 1–2

    Filing on the GST portal

    The LUT is filed online on the GST portal under Services > User Services > Furnish Letter of Undertaking. The form is filled with the exporter's details and digitally signed using the DSC of the authorised signatory.

  4. Days 2–3

    Acknowledgement and reference number

    Once submitted, the GST portal issues an ARN (Application Reference Number) and, within 24-48 hours, an acknowledgement confirming the LUT is on record. The LUT is valid from the date of filing until the end of the financial year.

What it costs

Our fee

What it costs, line by line

Starting at ₹2,000 for the LUT filing.

  • Professional fee
    ₹2,000
    Per LUT filing. Includes eligibility check, form drafting, witness coordination, portal submission, and acknowledgement download. Priced per LUT (typically one per financial year).
  • Government filing fee
    ₹0
    LUT filing is free with the government. There is no filing fee for RFD-11 on the GST portal.
  • DSC for authorised signatory (if new)
    ₹1,600
    Required for signing the LUT on the GST portal. Skipped if the authorised signatory already holds a valid Class-3 DSC (which is common for GST-registered businesses).
  • Annual renewal
    Same
    Same fee structure applies each year. Setting up a calendar reminder for early April ensures seamless renewal and no export interruption.

Your exact all-in number, including any DSC issuance needed, appears in the online form before any payment is taken.

After the LUT is accepted

What changes on the ground

Once the LUT is on record, the exporter moves from the pay-and-refund model to the zero-rated model. A few immediate items follow.

  • LUT active on GST portal
    The LUT is active from the filing date and valid until 31 March of the current financial year. The acknowledgement is downloaded and retained; it is required at the time of any refund or scrutiny.
  • Zero-rated invoices without IGST
    Export invoices are issued as 'export under LUT' with IGST rate as zero (not exempt, but zero-rated). The tax narration on the invoice references Rule 96A. This is the cash-flow benefit: no IGST paid upfront, no need to claim refund later.
  • GSTR-1 export details
    Every export invoice is reported in Table 6A of GSTR-1 for the tax period. The LUT number is quoted where the portal requires it. This links the export to the LUT for the government's tracking of zero-rated supplies.
  • GSTR-3B nil IGST on exports
    In GSTR-3B, export supplies are reported under Table 3.1(b) as 'zero-rated supplies with LUT'. IGST payable on these is nil. Input tax credit on inputs used for exports remains fully claimable, which becomes the refund pot for input tax refund applications.
  • Input Tax Credit refund claims
    Where input tax credit accumulates on inputs used for zero-rated supplies, refund applications can be filed in Form RFD-01 under Rule 89. The refund route (with LUT) allows recovery of accumulated ITC without any IGST payment being involved in the exports.
  • SOFTEX and FEMA reporting
    For IT/ITeS service exports, SOFTEX declarations continue as before. The LUT does not change SOFTEX requirements; it changes only the GST treatment. FEMA reporting through the bank's EDPMS also stays the same.
  • Annual renewal calendar set
    The LUT is valid only until 31 March of the current financial year. A new LUT must be filed for the next financial year, ideally before 1 April so the transition is seamless. Missing renewal means paying IGST on exports from 1 April onwards until the new LUT is filed.
What goes wrong in practice

Common mistakes to avoid

LUT filing is simple, but the consequences of small errors are disproportionately large because of the cash-flow impact.

  • Filing after the first export of the year

    An exporter starts a new financial year without renewing the LUT, and issues export invoices assuming zero-rated treatment. These invoices are actually subject to IGST, which must then be paid and claimed back as refund. File the LUT before 1 April to avoid this trap.

  • Missing the annual renewal

    LUT is valid until 31 March each year. On 1 April, without a fresh LUT, exports revert to IGST-paid treatment. Missed renewal for even one month means paying IGST on that month's exports and going through the refund cycle. Calendar discipline matters.

  • Confusing LUT with IEC

    IEC is the DGFT-issued Import Export Code. LUT is a GST-side undertaking. Both are separately required for exports: IEC to make cross-border shipments legally, LUT to make them without paying IGST upfront. Filing one without the other leaves the export half-compliant.

  • Charging IGST on invoices despite LUT

    Where the LUT is in place but the accounting software has not been reconfigured, invoices continue to show IGST at 18%. Customers claim the credit, the exporter pays IGST it did not need to, and the reconciliation gets messy. Configure the invoice template to show zero-rated treatment from the LUT effective date.

  • Not claiming input tax credit refund

    With LUT, exports are zero-rated but inputs used for exports carry input tax credit. This credit accumulates and is eligible for refund under Rule 89. Many small exporters never file the refund application and let the credit sit unused. Set up a quarterly refund cycle for meaningful cash recovery.

II.
Part Two

Understanding the LUT

The structural background, read at your pace, in any order.

The cash-flow calculation

With LUT vs without LUT

The single most important reason to file an LUT is cash flow. Understanding what the LUT saves in concrete terms clarifies why most exporters file it as soon as they can.

Without LUT, Rule 96 route

Every export invoice attracts IGST at 18%. The exporter pays IGST to the government at the time of GSTR-3B filing (20th of the following month). The IGST is then claimed as refund under Rule 96 by filing RFD-01. Refunds typically take 60-90 days. For a large exporter, this ties up 5-15% of monthly turnover as float.

With LUT, Rule 96A route

Export invoices are zero-rated. No IGST is paid at any stage on the export supply. Input tax credit on inputs remains eligible for refund (Rule 89), but no IGST outflow ever happens on the exports themselves. This saves 60-90 days of working capital tied up per shipment.

An example: ₹1 crore monthly exports

Without LUT: ₹18 lakh monthly IGST paid, refunded 60-90 days later. Average ₹36 lakh permanently tied up as float. With LUT: ₹0 IGST paid, ₹0 float. The LUT saves the interest cost of ₹36 lakh working capital, plus the operational overhead of tracking refund applications.

Why anyone would skip LUT

Some exporters, particularly those disqualified under Rule 96A (past tax evasion prosecution), have no choice but to use Rule 96. Others choose Rule 96 for accounting simplicity in specific situations. But for the vast majority of exporters, Rule 96A with LUT is materially better.

A crucial distinction

Zero-rated vs exempt supplies

GST terminology distinguishes between "zero-rated" and "exempt" supplies. Both look tax-free on the outward side, but the treatment of input tax credit is fundamentally different, which changes the total tax cost.

  • Zero-rated supplies (Section 16 IGST Act)

    Exports of goods or services, and supplies to SEZ. Tax rate on the outward supply is 0%. Input tax credit on inputs used for the supply is FULLY claimable. Where credit exceeds output tax (which it always does for pure exporters), it is refundable under Rule 89 or Rule 96.

  • Exempt supplies (Section 11 CGST Act)

    Specific goods or services notified as GST-exempt. Tax rate on the outward supply is 0% (or not applicable). But input tax credit on inputs used for exempt supplies is NOT claimable, it is treated as a cost. This is the crucial distinction from zero-rated.

  • Why the distinction matters

    An exporter of GST-exempt goods (unlikely, but conceptually possible) cannot claim ITC on inputs. An exporter of standard GST goods with LUT can claim full ITC and get refunds. This makes the LUT-route exporter meaningfully more profitable than the exempt-supply exporter, all other things equal.

An adjacent use case

Supplies to SEZ under LUT

Section 16 of the IGST Act treats supplies to a SEZ unit or a SEZ developer as zero-rated exports, even though the goods do not physically leave India. The LUT covers these SEZ supplies just as it covers standard cross-border exports.

  • DTA suppliers to SEZ units qualify

    Any Domestic Tariff Area (i.e., non-SEZ) supplier making goods or services supplies to a SEZ unit or developer can file LUT to make these supplies zero-rated. Both the goods flow and the service flow qualify.

  • No physical export required

    Unlike cross-border exports, SEZ supplies do not need a shipping bill or bill of entry. The zero-rated treatment is granted based on the SEZ status of the buyer. The LUT lets the supplier bill zero-IGST invoices; the SEZ buyer avoids claiming refund of paid IGST.

  • Documentation is different

    For SEZ supplies, the invoice references the SEZ endorsement letter (issued by the SEZ authority) rather than a shipping bill. The GSTR-1 reporting is under Table 6B for SEZ supplies (not Table 6A which is for exports). Getting the classification right at invoice time saves reconciliation trouble.

Discipline required

The annual renewal cycle

The LUT is valid only for the current financial year. This is probably the most operationally important rule to remember.

i.

Effective from filing, until 31 March

An LUT filed on 15 April 2026 is valid from 15 April 2026 to 31 March 2027. Exports before 15 April 2026 need either a prior LUT or IGST-paid treatment.

ii.

File early in the financial year

Ideally, the LUT for FY 2027-28 is filed between 1 April 2027 and 15 April 2027, so that from the first working day of April, exports are zero-rated. Filing later creates a gap where IGST has to be paid on exports of that gap period.

iii.

No automatic renewal

The GST portal does not auto-renew LUTs. Every year is a fresh application. Set a calendar reminder for the last week of March each year to file the new LUT before the year ends.

iv.

Same-year corrections possible

If details in the filed LUT need correction (say a changed witness or an updated address), the correct approach is to file a fresh LUT for the same year. The GST portal accepts multiple filings; the most recent one is treated as operative.

  1. i.

    Fill the online form

    Save and resume anytime. No pressure to finish in one sitting.

  2. ii.

    Review the scope and fee

    The exact all-in fee, the timeline, and what's included appear together before any payment.

  3. iii.

    Filing begins

    Your dashboard tracks every step. Every form is signed and certified by a Practising Company Secretary.