How to Apply

How to Apply for GST LUT for Exports. Step-by-Step

GST portal walkthrough for Form RFD-11 LUT. Eligibility, annual renewal, LUT vs bond, revocation triggers, service exports.

By Aaryan Kakani · · 8 min read

What Is LUT and Why Exporters Need It

Under GST, exports are treated as "zero-rated supplies" under Section 16 of the IGST Act. This means no tax is ultimately borne on exports, but the mechanism for achieving zero-rating gives exporters two choices:

  • A. Export with IGST payment. Pay IGST on the export invoice, then claim a refund later. This blocks working capital for 2. 6 months.
  • B. Export under LUT without IGST. Furnish a Letter of Undertaking (LUT) and export at zero tax. No IGST outflow, no refund wait. You can still claim refund of accumulated input tax credit (ITC) separately.

The LUT is filed using Form GST RFD-11 on the GST portal. It is a self-declaration by the exporter that they will fulfill the export obligation and meet the conditions of zero-rating. There is no fee, no officer approval, and no physical document. The entire process is online and instant.

Who Is Eligible to File LUT

Almost every registered taxpayer can file a LUT. The eligibility is deliberately broad because the government wants to encourage exports without blocking working capital.

Eligible

  • Any person registered under GST who intends to make zero-rated supplies (exports of goods or services, or supplies to SEZ units/developers).
  • Manufacturers, merchant exporters, service providers, and traders. All qualify.
  • No minimum turnover or export history is required. Even first-time exporters can file LUT before their first shipment.

Not Eligible (Must File Bond Instead)

Taxpayers who have been prosecuted for any offence under the CGST Act or the erstwhile indirect tax laws (Central Excise, Service Tax, Customs) where the amount of tax evaded exceeds Rs. 2.5 crore . Such persons must furnish a bond with a bank guarantee instead of LUT.

Note: this is "prosecuted," not merely "investigated" or "show-caused." A pending investigation or SCN does not disqualify you from filing LUT.

When to File LUT

LUT is valid for one financial year (April to March). You must file it in two scenarios:

ScenarioWhen to FileConsequence of Missing
Annual renewalBefore April 1 each yearExports after March 31 require IGST payment until new LUT is filed
First-time exporterBefore the first zero-rated supplyMust pay IGST on that export and claim refund later

Step-by-Step GST Portal Walkthrough

The entire process takes 5. 10 minutes. LUT approval is instant. There is no officer intervention or processing time. Here is exactly what to do.

Go to gst.gov.in and log in with your GSTIN, username, and password. If you have multiple GSTINs (for different states), log in with the GSTIN from which you intend to export.

From the dashboard, go to:

Services > User Services > Furnish Letter of Undertaking (LUT)

This opens the Form GST RFD-11 page.

Choose the financial year for which you want the LUT to be effective. If you are filing before April 1 for the upcoming year, select the next financial year. The dropdown shows only the current and next financial year.

The form is pre-populated with most of your entity details from your GST registration. You need to provide:

  • Entity details. GSTIN, legal name, and trade name are auto-filled. Verify they are correct.
  • LUT number of previous year. If this is a renewal, enter the ARN of your previous year's LUT. For first-time filers, leave blank.
  • Authorized signatory details. Select the authorized signatory from the dropdown. This person must be listed as an authorized signatory in your GST registration.
  • Self-declaration. A checkbox confirming that you have not been prosecuted for tax evasion exceeding Rs. 2.5 crore. Tick this box.
  • Witnesses. Provide names and addresses of two independent witnesses. These can be any two persons (employees, partners, CAs, etc.). No witness signature or verification is required online.

You can sign the form using either a Digital Signature Certificate (DSC) or Electronic Verification Code (EVC) via Aadhaar-linked OTP. Companies and LLPs must use DSC. Proprietorships, partnerships, and individuals can use either DSC or EVC. If using DSC, ensure the DSC utility (emSigner) is installed and the token is plugged in.

Click "Submit" . The system processes the form instantly. There is no officer review, no approval queue, and no waiting period. The LUT becomes effective immediately upon submission.

After submission, an Application Reference Number (ARN) is generated. Download and save the acknowledgment. You will need this ARN when filing your next year's LUT (as reference to the previous LUT) and for your records. The ARN also serves as proof that you had a valid LUT in place at the time of export.

LUT vs Bond. When You Need a Bond Instead

Most exporters use LUT because it is free and instant. A bond is required only in specific situations.

ParameterLUTBond
FormGST RFD-11 (online)Bond on stamp paper + bank guarantee
CostFreeStamp duty + bank guarantee charges (0.5-2% p.a.)
ProcessingInstant, auto-approvedRequires officer acceptance
Who must useAll eligible taxpayersPersons prosecuted for evasion > Rs. 2.5 Cr
When requiredBefore first export each FYWhen LUT is revoked or person is ineligible
Bank guaranteeNot requiredRequired, covering estimated tax on exports
ValidityOne financial yearUntil revoked or FY ends

LUT Revocation. Triggers and How to Handle

LUT revocation is uncommon but serious. The Commissioner of GST can revoke a LUT under Rule 96A(4) of the CGST Rules if:

  • The exporter fails to pay the tax due on the zero-rated supply within the time specified in a notice issued under the LUT conditions.
  • The exporter fails to comply with the conditions of the LUT. Primarily, the obligation to ensure that the export actually happens and foreign exchange is received.
  • The exporter is subsequently prosecuted for tax evasion exceeding Rs. 2.5 crore, making them ineligible for LUT.

What Happens After Revocation

  1. You receive a notice from the Commissioner stating the grounds for revocation.
  2. You must furnish a bond with a bank guarantee for the remaining period of the financial year to continue exporting without IGST.
  3. Alternatively, you can export with IGST payment and claim refund until the next financial year, when you can file a fresh LUT (if the grounds for revocation no longer exist).
  4. You may also challenge the revocation by filing a representation or appeal if you believe the revocation is unjustified.

Common Mistakes to Avoid

These are the errors we see most often among Indian exporters when it comes to LUT.

Forgetting annual renewal

LUT expires on March 31 every year. If you do not file a new LUT before April 1 and export in early April, those exports are not covered. You must pay IGST on them. Set a recurring reminder for mid-March.

Not covering SEZ supplies

LUT is not just for exports. Supplies to SEZ units and SEZ developers are also zero-rated. If you supply to SEZs without a valid LUT, you must charge IGST. Many exporters who also supply domestically to SEZs forget that LUT covers both.

Filing LUT after the export

LUT must be in place before the zero-rated supply. Filing LUT retroactively does not cover past exports. If you shipped goods on April 5 and filed LUT on April 10, the April 5 supply is not covered.

Filing under the wrong GSTIN

If you have registrations in multiple states, each GSTIN needs its own LUT. A LUT filed under your Maharashtra GSTIN does not cover exports from your Gujarat unit. File separately for each state registration from which you export.

Missing witness details

Form RFD-11 requires two witness names and addresses. While no verification is done, the form cannot be submitted without these fields. Have the details ready before you start.

DSC not configured

Companies and LLPs must use DSC. If the emSigner utility is not installed or the DSC token is not plugged in, submission will fail. Test your DSC setup before starting the LUT filing process.

What Happens If You Export Without LUT

Exporting without a valid LUT is not illegal. It just means you cannot use the "without payment of IGST" route. Here is what happens:

  1. You must pay IGST on the export invoice at the applicable rate (typically 5%, 12%, 18%, or 28% depending on the goods/services).
  2. For goods exporters: the IGST paid is automatically refunded through the shipping bill route. Once the customs system confirms the export (EGM filing by the shipping line), the refund is processed by ICEGATE and credited to your bank account. Timeline: 2. 4 weeks in most cases.
  3. For service exporters: you must manually file Form GST RFD-01 to claim refund of the IGST paid. This is a longer process, typically taking 2. 6 months including the deficiency memo cycle.
  4. Working capital impact: the IGST amount is blocked from the date of payment until refund. For a service exporter billing Rs. 50 lakh per month at 18% IGST, that is Rs. 9 lakh blocked for 2. 6 months.

LUT for Service Exporters

Service exporters (IT companies, consultants, designers, SaaS providers, etc.) need LUT just as much as goods exporters. Arguably more, because the IGST refund route for services is slower and more cumbersome than the shipping bill route for goods.

Key Points for Service Exporters

  • The LUT filing process is identical to goods exporters. Same form (RFD-11), same portal, same instant approval.
  • LUT covers all zero-rated service supplies, including those billed in foreign currency and received through normal banking channels.
  • With LUT, your export invoices carry zero IGST. Without LUT, you must charge IGST and then file Form RFD-01 for refund, which typically takes 2. 6 months.
  • Service exporters can claim refund of accumulated ITC (on rent, software, professional services, etc.) under Rule 89(4) even while using LUT for zero-rated billing.
  • Ensure your export invoices clearly mention "Supply meant for export under LUT without payment of IGST" along with the LUT ARN number. See our IT/software export compliance guide for invoice format requirements.

Frequently Asked Questions

Related resources

GST LUT Filing Guide

Detailed reference on LUT rules, conditions, and compliance requirements.

IGST Refund Process

How to claim IGST refund if you export with IGST payment instead of LUT.

IGST Refund vs LUT

Side-by-side comparison to help you choose the right export mechanism.

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