GST LUT Filing Guide for Exporters. Form RFD-11, Renewal & Common Errors

What Is LUT Under GST

LUT stands for Letter of Undertaking . It is a self-declaration filed by a GST-registered exporter on the GST portal, promising to fulfil all export obligations. Primarily that foreign exchange for the exported goods or services will be realised within the prescribed time limit.

The legal basis is Section 16(3) of the IGST Act, 2017 , read with Rule 96A of the CGST Rules . Under this provision, a registered person making a zero-rated supply (exports or supplies to SEZ) can do so without payment of integrated tax, provided they furnish a Letter of Undertaking or a Bond before making such supply.

Why does this matter? Without an LUT, every export shipment attracts IGST at the applicable rate. 5%, 12%, 18%, or 28% depending on the HSN classification. That IGST amount leaves your bank account immediately and sits with the government until the refund is processed, which typically takes 30 to 90 days and often stretches longer. For an exporter shipping Rs 50 lakh worth of goods at 18% GST, that is Rs 9 lakh of working capital locked up every single shipment.

With a valid LUT, you export at zero tax. No IGST is charged on the export invoice, no IGST is paid in GSTR-3B for that supply, and the shipping bill is filed without any IGST component. Your input tax credit (ITC) on domestic purchases accumulates and is claimed back separately via Form RFD-01. The net effect: your cash stays in your business instead of cycling through the government refund machinery.

Who Can File LUT. And Who Cannot

The eligibility criteria for filing an LUT are intentionally broad. The government wants exporters to use the LUT route because it reduces the refund processing burden on the department.

Eligible to file LUT

• Any person registered under GST who is making zero-rated supplies (exports of goods or services, or supplies to SEZ units/developers).
• No minimum turnover requirement. Even a first-time exporter with zero export history can file.
• No requirement to have been in business for a minimum period.
• Manufacturers, merchant exporters, service exporters, and e-commerce sellers are all eligible.
• Exporters with multiple GSTINs (multi-state registrations) can file separately for each GSTIN.

It is worth emphasising what does not disqualify you: pending investigations, show-cause notices, demand orders, or even a tax demand below the Rs 2.5 crore threshold. The bar is specifically "prosecution". Meaning the department has filed a criminal complaint, not merely raised a tax dispute. If you have received a show-cause notice but no prosecution has been launched, you remain eligible for LUT.

LUT vs Bond. When You Need a Bond Instead

Before the simplification of rules, all exporters had to furnish a Bond on non-judicial stamp paper along with a bank guarantee to export without paying IGST. The LUT replaced this requirement for most exporters. However, the Bond route still exists for specific situations.

The bank guarantee requirement for Bonds is significant. Banks typically charge 1-3% per annum on the guarantee amount, plus processing fees. For an exporter with annual exports of Rs 5 crore, a bond value of Rs 5 crore with a 15% bank guarantee means Rs 75 lakh locked as guarantee, costing Rs 75,000 to Rs 2.25 lakh per year in bank charges alone. This is why the LUT route is overwhelmingly preferred.

Filing LUT on the GST Portal. Step by Step

Filing Form RFD-11 is one of the simplest processes on the GST portal. The entire process takes under 10 minutes if you have your credentials and DSC ready.

Step-by-step process

1. 01 Log in to the GST portal at gst.gov.in using your GSTIN credentials. Navigate to Services → User Services → Furnish Letter of Undertaking (LUT) .
2. 02 Select the financial year. Choose the financial year for which you are filing the LUT. For FY 2026-27, select "2026-27" from the dropdown. The system will show if an LUT already exists for the selected year.
3. 03 Fill in the LUT details. The form is pre-populated with your GSTIN, legal name, and trade name. You need to provide: (a) names and addresses of two independent witnesses, and (b) the place of filing. The witnesses do not need to be present or sign anything on the portal. You are simply declaring their details.
4. 04 Self-declaration. Tick the checkbox confirming that you have not been prosecuted for tax evasion exceeding Rs 2.5 crore. This is the key eligibility criterion. If you cannot tick this box, you must go the Bond route.
5. 05 Verification and submission. You can submit using either a Digital Signature Certificate (DSC) or an Electronic Verification Code (EVC) via Aadhaar OTP. Companies and LLPs must use DSC. Proprietorships and partnerships can use either DSC or EVC.
6. 06 Acknowledgement. Upon successful submission, the portal generates an ARN (Application Reference Number). The LUT is typically accepted automatically. There is no approval queue or officer-level scrutiny in most cases. Download the acknowledgement for your records.

Annual Renewal. The April 1 Deadline

An LUT is valid for one financial year only. From April 1 to March 31. There is no auto-renewal. Every single year, without exception, you must file a fresh Form RFD-11 on the GST portal for the new financial year.

The ideal filing date is April 1 (or the first working day of April if April 1 falls on a weekend or holiday). There is no formal grace period defined in the law. The moment the new financial year begins and your old LUT expires, any export shipment made without a valid LUT will require IGST payment.

What happens if you miss renewal

• Every export between April 1 and the date you finally file the new LUT will attract IGST at the applicable rate .
• You will need to pay the IGST in your GSTR-3B and then claim it back through the shipping bill refund route, locking up working capital for 30-90+ days.
• The new LUT, once filed, is prospective only . It does not retroactively cover exports made before the filing date.
• If you have already shipped goods in April without IGST and without a valid LUT, you could face a demand for IGST plus interest at 18% per annum from the GST department.

LUT Validity. Financial Year and GSTIN Basis

Understanding LUT validity is straightforward but the implications of getting it wrong are significant.

Common Mistakes Exporters Make with LUT

The LUT process itself is simple, but the mistakes around it can be expensive. Here are the errors we see most frequently among Indian exporters.

Mistake 1: Not filing LUT before the first export of the year

The most common error. An exporter ships goods in April without realising the previous year's LUT has expired. The shipment defaults to IGST payment, and the exporter only discovers the issue when they try to file GSTR-1 or when the customs system flags the shipping bill. By then, the IGST is already due.

Mistake 2: Filing LUT for the wrong financial year

Some exporters accidentally select the previous financial year in the RFD-11 dropdown, especially when filing in March or early April. The portal may accept it (as a duplicate or late filing for the old year), but it does not create an LUT for the new year. Always double-check the financial year selected.

Mistake 3: Not filing LUT for every GSTIN

Businesses with multiple state registrations often file the LUT for their primary GSTIN and forget the others. Each GSTIN needs its own LUT. An export from a GSTIN without a valid LUT requires IGST payment, regardless of whether another GSTIN under the same PAN has a valid LUT.

Mistake 4: Not downloading the acknowledgement

The LUT acknowledgement with ARN is your proof of filing. Without it, you may face queries from customs or the GST department about whether a valid LUT existed at the time of export. Always download and save the acknowledgement PDF immediately after filing.

Mistake 5: Assuming LUT covers deemed exports

LUT covers exports of goods/services and supplies to SEZ. It does not cover deemed exports under Section 147 of the CGST Act (such as supplies against advance authorisation or EPCG). Deemed exports follow a separate mechanism, and assuming LUT coverage can lead to incorrect invoicing.

Mistake 6: Not realising foreign exchange within the time limit

The LUT comes with a condition: export proceeds must be realised within the time prescribed under FEMA (currently 9 months from the date of export, extendable by RBI). If you fail to realise the forex within this period, you must pay IGST on that export along with interest at 18% per annum from the date of export. This can also trigger LUT revocation. Track your outstanding export receivables diligently.

Mistake 7: Shipping without checking LUT status on the portal

Sometimes the LUT submission fails silently due to portal glitches, DSC errors, or session timeouts. The exporter assumes the LUT is in place because they went through the motions, but no ARN was generated. Before your first export of each financial year, log into the GST portal and verify that the LUT for the current year shows as "Active" with a valid ARN.

LUT and E-Commerce Exports

E-commerce exports from India have grown exponentially, with platforms like Amazon Global Selling, eBay, Etsy, and Shopify enabling small businesses to sell internationally. The LUT requirement applies equally to e-commerce exporters, but there are additional considerations.

LUT for e-commerce exports

• CSB-V (Courier Shipping Bill V) is the customs document for e-commerce exports sent by courier. Not CSB-IV, which is the non-commercial form for documents, gifts and samples and carries no incentive claim. LUT is required for courier e-commerce shipments too if you want to export without paying IGST.
• Marketplace sellers (selling through Amazon, Flipkart for cross-border, etc.) must have their own LUT filed under their GSTIN. The marketplace does not file LUT on your behalf.
• Aggregated shipments through logistics partners like DHL eCommerce, FedEx, or India Post still require individual shipping bills and a valid LUT for each seller GSTIN.
• Small-value exports do not get an exemption from LUT requirements. Even if your individual consignment value is Rs 5,000, you need a valid LUT to export without IGST.

E-commerce exporters face a unique challenge with forex realisation. Marketplace payouts often come in consolidated amounts that do not map 1:1 to individual shipping bills, making the forex realisation tracking more complex. Ensure your payment reconciliation process can link marketplace payouts to specific export invoices for EDPMS closure.

LUT Revocation. When the Department Takes It Back

An LUT is not irrevocable. The jurisdictional GST commissioner can revoke your LUT under specific circumstances defined in Rule 96A(4) of the CGST Rules.

Grounds for LUT revocation

• Failure to pay IGST when export proceeds are not realised. If you do not realise foreign exchange within the prescribed time (9 months under FEMA) and fail to pay the applicable IGST plus 18% interest, your LUT can be revoked.
• Prosecution initiated after LUT filing. If prosecution for tax evasion exceeding Rs 2.5 crore is initiated against you after the LUT was accepted, the department can revoke the LUT.
• Non-compliance with LUT conditions. Failure to meet any of the undertakings given in the LUT, including maintaining proper records and making goods available for inspection.

What happens after revocation

Once your LUT is revoked, you cannot export without payment of IGST unless you furnish a Bond with a bank guarantee. The revocation is communicated through an order on the GST portal, and you are given an opportunity to be heard before the final order is passed.

Appeal process

If you believe the revocation is unjustified, you can appeal before the Appellate Authority under Section 107 of the CGST Act within three months from the date of the revocation order (extendable by one month on sufficient cause). During the appeal, you may request the appellate authority to stay the revocation order, though this is discretionary. In the meantime, you must either pay IGST on exports or furnish a Bond to continue exporting without IGST payment.

LUT Compliance Checklist

Use this checklist at the start of each financial year and before any major export shipment to ensure your LUT compliance is watertight.

10-Point LUT compliance checklist

• File Form RFD-11 on or before April 1 for the new financial year. Set a calendar reminder for March 25.
• File a separate LUT for each GSTIN if you have multi-state registrations.
• Download and save the LUT acknowledgement with ARN for every filing.
• Verify LUT status on the GST portal shows "Active" before making the first export of the financial year.
• Ensure your DSC is valid and registered on the GST portal (for companies and LLPs) before the renewal window.
• Track forex realisation for every shipping bill. Ensure proceeds are received within 9 months (FEMA deadline).
• File Form RFD-01 monthly or quarterly to claim accumulated ITC refund. Do not let ITC pile up.
• Keep witness details (name and address of two independent witnesses) readily available for quick filing.
• Monitor any show-cause notices or prosecution proceedings that could affect LUT eligibility.
• Reconcile GSTR-1 Table 6A with shipping bills monthly to ensure export data matches and ITC refunds are not delayed.

Frequently Asked Questions

Can a new exporter file LUT immediately after getting GST registration?

Yes. Any GST-registered person can file an LUT in Form RFD-11 as long as they have not been prosecuted for tax evasion exceeding Rs 2.5 crore. There is no minimum turnover, export history, or waiting period. You can file the LUT on the same day you receive your GSTIN and begin exporting without paying IGST.

What happens if I export without a valid LUT in place?

If you export without a valid LUT, the shipment is treated as a regular taxable supply. You must pay IGST at the applicable rate on that export invoice and report it in GSTR-3B. You can claim the IGST refund through the shipping bill route, but your working capital remains blocked until the refund is processed (typically 30-60 days, often longer). File the LUT immediately to cover future shipments.

Is LUT filing free of cost on the GST portal?

Yes. There is no government fee for filing Form RFD-11. The GST portal does not charge anything for LUT acceptance. Your only costs are indirect: the time to log in and fill the form (under 10 minutes), and the DSC or Aadhaar OTP used for verification. If you use a CA or GST practitioner to file on your behalf, their professional fee is the only expense.

Do I need a separate LUT for each GSTIN if I have registrations in multiple states?

Yes. LUT is GSTIN-specific, not PAN-specific. If your business has GST registrations in Maharashtra, Gujarat, and Tamil Nadu, you must file a separate Form RFD-11 for each GSTIN. Each LUT is valid only for exports made from that particular state registration. Missing an LUT for even one GSTIN means exports from that state will require IGST payment.

Can I file LUT after the start of the financial year, say in June, and have it cover exports from April?

No. The LUT is effective from the date of filing, not retrospectively from April 1. If you file the LUT on June 15, exports made between April 1 and June 14 are not covered. For those shipments, you would have had to pay IGST. The LUT filed on June 15 covers exports from that date until March 31 of that financial year. This is why filing on April 1 (or the first working day) is critical.

What is the difference between LUT and a Bond for exports?

An LUT is a simple self-declaration filed online via Form RFD-11 with no financial security. A Bond requires execution on non-judicial stamp paper and a bank guarantee (typically 15% of the bond value). Bonds are required only when the exporter has been prosecuted for tax evasion exceeding Rs 2.5 crore or when the LUT has been revoked by the GST department. For the vast majority of exporters, LUT is sufficient and no bond is needed.

Does LUT cover deemed exports or supplies to SEZ units?

LUT covers supplies to SEZ units and SEZ developers without payment of IGST, as these are also treated as zero-rated supplies under Section 16 of the IGST Act. However, deemed exports (supplies under Section 147 of CGST Act, such as supplies against advance authorisation) are not covered by LUT. Deemed exports follow a different refund mechanism under Rule 89(4) of CGST Rules.

Can my LUT be revoked? What are the grounds for revocation?

Yes. The GST department can revoke your LUT if: (a) you fail to pay the applicable IGST plus interest within the time limit when export proceeds are not realised within the prescribed period; (b) you are found to have been prosecuted for tax evasion exceeding Rs 2.5 crore after the LUT was filed; or (c) you fail to comply with the conditions of the LUT. Upon revocation, you must furnish a bond with a bank guarantee for future exports. You can appeal the revocation before the appellate authority within 30 days.

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Update history

• 2026-08-12 First published.