What is an LUT in GST?
An LUT is an undertaking in Form GST RFD-11 that you will meet the export conditions in Rule 96A of the CGST Rules. Once it is filed, you can make zero-rated supplies without paying IGST.
Exports and supplies to SEZ units or developers for authorised operations are zero-rated under section 16 of the IGST Act, 2017. Section 16(3) gives you two routes. You can supply under a bond or LUT without paying IGST and claim a refund of unused input tax credit, or you can pay IGST and claim that IGST back as a refund.
The LUT route keeps your cash with you. Notification 37/2017-Central Tax opened it to all registered persons except those prosecuted for large tax evasion, who must give a bond instead.
LUT for FY 2026-27: when to file
File the LUT for FY 2026-27 before you make your first export or SEZ supply of the year. The law sets no fixed last date, but the undertaking has to be in place when the supply is made.
Each LUT covers one financial year. The portal marks it Expired at the end of that year, so an LUT filed for FY 2025-26 stopped covering your exports on 31 March 2026. Filing for FY 2026-27 is open on the portal now.
If you have already exported in FY 2026-27 without an LUT, file it now and read "Exported before filing your LUT?" below. For FY 2027-28, file in March 2027 so exports can continue from 1 April 2027.
If your GSTIN changes, for example after a change in constitution that needs a new registration, file a fresh LUT on the new GSTIN for the rest of the year.
Who can file an LUT, and who cannot
Any GST-registered person who wants to export or supply to an SEZ without paying IGST can file an LUT. The only exclusion is a person prosecuted for tax evasion of ₹250 lakh (₹2.5 crore) or more.
| Situation | Route |
|---|---|
| Registered exporter of goods | LUT |
| Registered exporter of services, including freelancers and software exporters | LUT |
| Registered supplier to an SEZ unit or developer for authorised operations | LUT |
| Prosecuted under GST or an earlier tax law for evasion of ₹250 lakh or more | Bond, with a bank guarantee where required, instead of an LUT |
| Composition taxpayer | Not available: composition taxpayers cannot make inter-state supplies, and exports count as inter-state supplies |
| Business without GST registration | No LUT, because RFD-11 is filed from a GSTIN |
An LUT is filed per GSTIN. If you export from registrations in two states, each GSTIN files its own.
LUT or pay IGST and claim a refund?
For most exporters, the LUT is better because no tax leaves your account. The IGST route puts tax into the government's hands first and returns it only after a refund is processed.
| Point | Export under LUT | Export with IGST paid |
|---|---|---|
| Tax on the export invoice | None | IGST at the applicable rate |
| Cash tied up | None on the export | The IGST, until refunded |
| What you claim back | Unused input tax credit, through RFD-01 | The IGST paid (goods: shipping bill route; services: RFD-01) |
| Annual step | RFD-11 each financial year | None |
| Government fee | None | None |
A simple illustration: a software exporter billing ₹10,00,000 a month at 18% would pay ₹1,80,000 of IGST on every invoice under the refund route and wait for it to come back. Under an LUT, that ₹1,80,000 stays in the business. Credit on your own purchases can still be refunded under either route; see our GST refund service.
LUT for freelancers, software and service exporters
A freelancer or agency billing foreign clients needs an LUT to invoice without IGST, provided the service qualifies as an export and the business is GST-registered. If the service is not an export, GST applies as on a domestic sale, LUT or not.
When a service counts as an export
Under section 2(6) of the IGST Act, a supply of services is an export only if all five conditions are met:
- the supplier is located in India;
- the recipient is located outside India;
- the place of supply is outside India;
- you receive payment in convertible foreign exchange, or in Indian rupees where the RBI permits it;
- you and the recipient are not merely establishments of the same person, such as an Indian company billing its own foreign branch.
The place of supply is usually the recipient's location, but section 13 of the IGST Act has special rules for some services, so check yours before invoicing. On condition 4, CBIC Circular 202/14/2023-GST confirmed that rupee payments received through Special Rupee Vostro Accounts permitted by the RBI qualify. Keep the bank's inward remittance evidence (such as a FIRC) for every invoice.
Do you need GST registration at all?
A supplier of services only, including exports, does not have to register until aggregate turnover crosses ₹20 lakh (₹10 lakh in special category states), under Notification 10/2017-Integrated Tax. Export turnover counts towards aggregate turnover.
Registering voluntarily below that limit lets you file an LUT and claim refunds of GST paid on your laptop, software subscriptions and co-working rent. For registration, see our GST registration service. For income tax on foreign earnings, see ITR for freelancers.
What you undertake under Rule 96A
Filing RFD-11 binds you to three conditions. Break one and the IGST becomes payable with interest.
- Goods: export them within 3 months of the export invoice date, or within any longer period the Commissioner allows.
- Services: receive payment within 1 year of the invoice date, or within any longer period the Commissioner allows.
- Failure: if a deadline is missed, pay the IGST with interest at 18% a year (section 50(1)) within 15 days after the deadline.
If you do not pay, the facility to export under the LUT is withdrawn until you pay the amount due. For exports of goods, CBIC has clarified that realisation of payment is not a condition for the GST refund; the one-year payment condition applies to services.
LUT filing fee
Our professional fee is ₹999 for filing your LUT for one financial year. There is no government fee for Form RFD-11.
| Fee | Amount |
|---|---|
| Regikart professional fee, LUT in Form RFD-11 for one GSTIN and one financial year | ₹999 |
| Government fee for Form RFD-11 | No government fee |
Professional fees exclude GST at 18%. Government fees, where they apply, are paid at actuals to the department and are shown separately. Fees verified on 21 September 2026.
Interest under Rule 96A is not a fee. It arises only if an export condition fails, and it is paid to the government.
What is included
- Eligibility check: registration status, composition status and any prosecution exclusion
- A check that your service exports meet the section 2(6) conditions, with notes on any that do not
- RFD-11 preparation: financial year, undertakings and witness details
- Filing with the authorised signatory's DSC or EVC
- ARN and acknowledgement PDF sent to you, with the invoice wording for exports under LUT
- A reminder to file the next year's LUT before 1 April
How to file an LUT in Form RFD-11
RFD-11 is filed online on gst.gov.in in five steps. There is nothing to submit on paper.
- Open the form. Log in and go to Services, then User Services, then Furnish Letter of Undertaking (LUT). Select the financial year, here 2026-27.
- Upload an older LUT if needed. If an earlier LUT was approved manually, you can upload it (one file, up to 2 MB) so your records are complete online.
- Accept the undertakings. Tick the self-declaration checkboxes that reproduce the Rule 96A conditions.
- Add two independent witnesses. Enter each witness's name, address and occupation.
- Sign and file. Preview the form, then sign with the DSC or EVC of the primary or another authorised signatory. You can save a draft for up to 15 days.
Download the LUT acknowledgement and ARN
Once filed, the portal generates an ARN and an acknowledgement, and sends confirmation by SMS and email. To download it later, go to Services, then User Services, then View My Submitted LUTs, and open the LUT for the year using the ARN. Keep the PDF with your export records.
What the status on the portal means
| Status | Meaning |
|---|---|
| Submitted | Filed; ARN generated |
| Pending for Clarification | The officer has asked for a clarification |
| Approved or Rejected | The officer has acted on it |
| Deemed Approved | No action by the officer within 3 working days |
| Expired | The financial year has ended |
If the LUT option is disabled for your GSTIN, only the jurisdictional officer can enable it again. We write to the officer for you.
Details and documents you need
You need access to the GST portal, witness details and a signatory who can sign. RFD-11 does not ask for an IEC or export documents.
- GST portal login for the GSTIN that will export
- Name, address and occupation of two independent witnesses
- DSC of the authorised signatory (companies and LLPs) or EVC through the registered mobile
- Previous year's LUT, only if it was approved manually and you want it on record
- For service exporters: a sample contract or invoice, so we can check the section 2(6) conditions
Shipping goods? You also need an IEC from DGFT, which is separate from GST; see IEC registration.
Exported before filing your LUT?
If you exported without paying IGST and had no LUT in place, CBIC Circular 37/11/2018-GST says the benefit of zero-rating should not be denied where the export is established. The delay in furnishing the LUT may be condoned, and the LUT facility allowed after the event, depending on the facts.
In practice, file the LUT for the year at once and keep proof of each export: shipping bills for goods, and remittance evidence for services. If an officer raises the point, we prepare the GST notice reply citing the circular. The alternative is to pay IGST with interest on those invoices and claim it back through the refund route.
Do not keep exporting without an LUT on the strength of the circular. Condonation depends on the facts of each case.
After the LUT: invoices and refunds
Every export invoice under an LUT must carry the endorsement required by Rule 46: "supply meant for export or supply to SEZ unit or SEZ developer for authorised operations under bond or letter of undertaking without payment of integrated tax", adapted to your supply. Report these supplies as zero-rated in GSTR-1 and GSTR-3B.
Credit on your inputs builds up because your exports carry no tax. You can claim it back through RFD-01 within two years; see GST refund. Our GST return filing service keeps your returns in line with the refund figures.
Exporting goods as well? See how to register your AD code with customs for each port you ship from, and, for agricultural and processed food products, the RCMC from your export promotion council, APEDA.
Why Regikart for LUT filing
Regikart is a CA and CS firm serving 250+ clients from offices in Kolkata (head office), Delhi and Bengaluru. Every LUT is prepared and filed under a Chartered Accountant's review.
- We check the export, not only the form: section 2(6) conditions for services, composition status and the prosecution exclusion.
- Fixed fee: ₹999 for each GSTIN and year, no government fee.
- The full exporter setup: GST registration, IEC, monthly returns and refunds with one team.