Filing of LUT on GST Portal

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Filing of LUT on GST Portal

Every registered exporter who ships goods or services out of India — or supplies to an SEZ developer or unit — has a binary choice: pay IGST upfront and wait weeks or months for a refund, or file a Letter of Undertaking (LUT) in Form GST RFD-11 and export with zero IGST cash outflow. The LUT route, enabled by Rule 96A of the CGST Rules 2017, is almost always the right answer. For FY 2026-27, the LUT should be filed on or before 31 March 2026. This guide walks you through every step — eligibility, filing procedure, post-filing obligations, and the real cost of getting it wrong.

What a Letter of Undertaking Actually Does (and Does Not Do)

An LUT is not a licence or a permission slip. It is a formal undertaking to the Government of India that you will complete the export and realise foreign exchange within prescribed timelines — and if you do not, you will pay the IGST plus interest out of your own pocket. By giving this undertaking, you earn the right to export under Section 16(3)(b) of the IGST Act 2017 without paying IGST at the time of invoicing or shipment.

The alternative — exporting under a bond backed by a bank guarantee — is more cumbersome and ties up a bank guarantee limit that most exporters cannot afford to waste. The LUT route eliminates that friction entirely.

What the LUT does not do: it does not exempt your domestic purchases from GST. If you have GST-paid inputs (raw material, freight, professional services), your Input Tax Credit (ITC) accumulates and you must separately claim a refund of that accumulated ITC under Section 54(3) of the CGST Act 2017. The LUT simply ensures the export invoice itself carries zero IGST.

Governing Law and Key Provisions You Must Know

Understanding the legal scaffolding prevents errors in interpretation:

• Section 16 of the IGST Act 2017 defines "zero-rated supply." Exports of goods or services, and supplies to SEZ developers or SEZ units, are zero-rated by statute — not by circular or notification.
• Rule 96A of the CGST Rules 2017 prescribes the bond/LUT mechanism, the conditions for filing, and the consequence of breach.
• Form GST RFD-11 is the prescribed form for filing the LUT on gst.gov.in.
• Notification No. 37/2017-Central Tax, as amended, removed the original eligibility restrictions (the Rs. 1 crore FIRC threshold and "status holder" requirement), making every registered exporter eligible except those specifically barred.

One operational note: from FY 2023-24, the GST portal began pre-populating certain fields in the LUT form based on prior-year data. This does not mean auto-renewal — the formal submission must be completed afresh each year.

Who Is Eligible to File an LUT — and Who Must File a Bond Instead

Eligible

Any person registered under the CGST Act who:

• Exports goods or services outside India, or
• Makes zero-rated supplies to SEZ developers or SEZ units

is eligible to file an LUT, regardless of annual turnover, export volume, or whether the entity is a start-up, MSME, or large corporate.

Not Eligible — Must File Bond with Bank Guarantee

A registered person who has been prosecuted for any offence under the CGST Act, IGST Act, UTGST Act, or the corresponding state GST law, where the amount of tax evaded or the amount of the offence exceeds Rs. 2,50,00,000 (Rs. 2.50 crore), cannot file an LUT. They must furnish a bond in Form GST RFD-11, backed by a bank guarantee for an amount as prescribed.

The operative word is "prosecuted" — a show-cause notice, a demand order, or a recovery notice does not disqualify you. A formal criminal complaint filed before a Magistrate's court under Section 132 of the CGST Act is what creates the bar. If such proceedings are concluded in your favour, or are compounded, eligibility is restored.

Documents and Information to Gather Before You Start

The portal session for LUT filing takes roughly 10 minutes if everything is ready. Collect the following before logging in:

1. GSTIN login credentials for the specific registration at which the export invoice will be raised
2. A valid Digital Signature Certificate (DSC) registered on the portal — mandatory for companies and LLPs; EVC (via OTP) is acceptable for proprietors and partnerships
3. Name, complete address (including PIN code), and occupation of two independent witnesses — they do not sign the online form, but their details are captured in RFD-11
4. Previous year's LUT ARN for reference (the portal may display it for context)
5. If filing for multiple GSTINs, login credentials for each registration separately — there is no group-level LUT

Step-by-Step: How to File LUT in Form RFD-11 on the GST Portal

Step 1 — Log In to gst.gov.in

Go to gst.gov.in → click Login in the top-right corner → enter your GSTIN-linked username and password → complete the CAPTCHA. Ensure you are on the production portal, not the sandbox.

Step 2 — Navigate to the LUT Section

From the post-login dashboard: Services → User Services → Furnish Letter of Undertaking (LUT)

Step 3 — Select the Financial Year

From the dropdown menu at the top of the form, select FY 2026-27. This single dropdown is the single most common error point across all LUT filings. Do not let the default value persist — verify explicitly before moving forward.

Step 4 — Review Auto-Populated Registration Details

The portal pre-fills your legal name, trade name (if any), GSTIN, and registered address from your GST registration record. Cross-check these against your GST Registration Certificate (Form REG-06). Any mismatch needs to be resolved through an amendment before filing the LUT.

Step 5 — Tick the Three Mandatory Declarations

Form RFD-11 requires you to affirm all three declarations:

• Declaration 1: You have not been prosecuted for any offence under the GST Acts where the tax amount exceeds Rs. 2.50 crore.
• Declaration 2: You undertake to export goods within three months of the tax invoice date and to realise export proceeds in convertible foreign exchange within the period prescribed under the Foreign Exchange Management Act (FEMA), 1999, or such extended period as the Reserve Bank of India (RBI) may allow.
• Declaration 3: You acknowledge that failure to comply with the above conditions will render you liable to pay the IGST that would have been payable on the export, along with interest at 18% per annum from the date of the tax invoice.

Read all three before ticking. If there is a pending prosecution matter, even one you believe is frivolous, consult your CA before clicking through.

Step 6 — Enter Witness Details

Enter the following for both Witness 1 and Witness 2:

• Full name (as per government ID)
• Complete address with PIN code
• Occupation or designation

These witnesses need not be present physically. Their details are entered by you in the form. They are not required to provide any digital signature. Maintain a standard template with pre-approved witness details so this step takes under two minutes.

Step 7 — Sign and Submit

• Companies and LLPs: Click Sign with DSC → a pop-up for your DSC token appears → select the authorised signatory's certificate → verify and submit.
• Proprietors and Partnerships: Click Sign with EVC → a one-time password is dispatched to the registered mobile number and email ID of the primary authorised signatory → enter the OTP within the validity window → submit.

If your DSC plug-in is outdated, the portal will throw an error. Update the GST portal's DSC plug-in from the Help and Taxpayer Facilities section before the filing date.

Step 8 — Download the ARN and LUT Certificate

Immediately after successful submission:

• An Acknowledgement Reference Number (ARN) appears on screen — note it and take a screenshot.
• A LUT Certificate in PDF format is auto-generated and is available under Services → User Services → View / Download LUT.

Download the PDF, rename it with the GSTIN and FY (e.g., 27AABCS1234A1ZC_LUT_2026-27.pdf), and store it in three places: your cloud folder, the export documentation file for the FY, and a copy emailed to your accounts team. Banks, freight forwarders, customs officers, and GST refund officers will ask for this document throughout the year.

LUT Validity, the 1 April Deadline, and What Happens If You Miss It

The LUT is valid for exactly one financial year — 1 April to 31 March. It does not auto-renew. A fresh RFD-11 must be filed each April.

The practical rule is simple: file by 31 March each year so that the first export invoice of the new FY — even if raised on 1 April — is covered.

If you begin raising export invoices on 1 April 2026 without having filed the LUT for FY 2026-27, each of those invoices is technically uncovered. The export is treated as if made without the required undertaking, making IGST liable on those invoices from the invoice date.

If you miss the start of the FY: The portal allows filing an LUT at any point during the FY. Once filed — even in July or October — the LUT covers the entire FY from 1 April. However, export invoices raised between 1 April and the actual LUT filing date remain exposed. The department may take a view that IGST was payable on those invoices during the gap period. In practice, the risk of interest being raised on this gap is material, particularly if an audit or scrutiny assessment is triggered.

The risk-free approach: treat 31 March as a hard deadline, with an internal reminder triggered on 15 March to check DSC validity and confirm witness details are in order.

Your Post-Filing Obligations: The FEMA Timeline Rules

Signing the LUT is not the end of the story. It is the beginning of ongoing compliance obligations. Two conditions must be satisfied after each export invoice:

For Export of Goods

1. The goods must physically cross the customs barrier and the shipping bill must be filed within three months of the date of the tax invoice. If a shipment is unavoidably delayed beyond three months, you must apply to the GST Commissioner for an extension before the deadline, not after.
2. Export proceeds must be realised in convertible foreign exchange within the period applicable under FEMA regulations — generally nine months from the date of the invoice for merchandise exports. The RBI can grant extensions in documented cases (natural disaster, force majeure, buyer insolvency, etc.), but these must be applied for proactively through your authorised dealer bank.

For Export of Services

Export proceeds must be received in convertible foreign exchange within the period specified under FEMA as applicable to services exports. Cross-check the exact period with your authorised dealer bank for your specific service category, and build an early-warning trigger at the seven-month mark.

Consequence of Breach

If the realisation deadline is missed:

• IGST becomes payable on the full value of the export invoice, calculated at the applicable rate.
• Interest at 18% per annum under Section 50 of the CGST Act accrues from the date of the tax invoice — not from the breach date, but from the invoice date.
• The LUT facility can be revoked on repeated breach, requiring the exporter to move to the bond-with-bank-guarantee route for future exports.

Worked Examples: The Real Rupee Cost of Getting This Wrong

Example A — Late LUT Filing

A Bengaluru-based IT services firm raises its first export invoice of FY 2026-27 on 2 April 2026 for Rs. 25,00,000 to a UK client. The accounts team forgot to file the LUT and only files it on 20 April 2026 — an 18-day gap.

• IGST applicable on IT services (SAC 998314) @ 18%: Rs. 25,00,000 × 18% = Rs. 4,50,000
• Interest @ 18% p.a. for 18 days: Rs. 4,50,000 × 18% × 18/365 = Rs. 3,995
• If the firm raised five such invoices during those 18 days, total IGST exposure = Rs. 22,50,000, plus interest of Rs. 19,973

The refund of that IGST (once the LUT is filed and the export is established) will eventually come through, but it blocks working capital for weeks and consumes hours of compliance effort. The filing itself would have taken 10 minutes on 31 March.

Example B — Forex Not Realised Within Nine Months

A Ludhiana garment exporter ships goods worth Rs. 60,00,000 on 10 July 2025 under a validly filed LUT. The overseas buyer delays payment due to a dispute; forex is finally received on 25 April 2026 — 289 days from the invoice date.

• Nine-month deadline (from 10 July 2025): 9 April 2026
• Actual receipt: 25 April 2026 — 16 days late
• IGST @ 12% on Rs. 60,00,000: Rs. 7,20,000
• Interest @ 18% p.a. on Rs. 7,20,000 for 289 days (from the invoice date of 10 July 2025): Rs. 7,20,000 × 18% × 289/365 = Rs. 1,02,630

Total unplanned liability: Rs. 8,22,630 — on a shipment where the LUT was correctly filed. The only failure was not tracking the forex realisation deadline. An RBI extension applied for at the seven-month mark — or a proactive legal notice to the buyer at month five — would have cost a fraction of this.

The discipline this demands: maintain a simple export register with four columns: invoice number, invoice date, invoice value in Rs., and forex realisation date. Flag every invoice that passes the seven-month mark without a receipt date. Escalate immediately to your banker.

Multi-GSTIN Entities and SEZ Supplies: What Changes

Multiple GSTINs Across States

The LUT is registration-specific, not entity-specific. If your company has GSTINs in Maharashtra, Karnataka, and Tamil Nadu, each GSTIN needs its own LUT filing. There is no consolidated or group LUT. Build a multi-GSTIN compliance calendar showing the LUT filing deadline (31 March) for each state registration, with the responsible person identified for each location.

Supplies to SEZ Developers and SEZ Units

The same LUT filed for exports also covers supplies to SEZ developers or SEZ units — you do not file a separate undertaking for SEZ. However, the documentation burden for SEZ supplies is different. Retain:

• The SEZ unit's valid Letter of Approval (LoA) issued by the Development Commissioner
• The SEZ-specific endorsement on the supply invoice, or the authorised courier receipt / gate-entry document issued by the SEZ
• Proof of receipt of supply from the SEZ unit (Form A or the relevant SEZ acknowledgement)

These documents are routinely sought during GST audits, refund scrutiny, and DGFT verification.

What the LUT Does Not Cover — Deemed Exports

Supplies to Export-Oriented Units (EOUs), holders of Advance Authorisation, or EPCG licence holders that qualify as "deemed exports" under the Foreign Trade Policy are not zero-rated supplies under Section 16 of the IGST Act. They are taxable domestic supplies eligible for a refund of tax paid. The LUT mechanism does not apply to deemed exports. Do not raise a zero-IGST invoice to an EOU citing an LUT — that is an incorrect classification.

Common Mistakes and How to Fix Them

The following errors come up repeatedly across practices. Review this list against your own process:

• Selecting the wrong FY in the portal dropdown. If you are filing in late March 2026 for FY 2026-27, the dropdown must show 2026-27 — not the current year 2025-26. Verify before submitting.
• Using EVC for a company or LLP. The portal blocks EVC authentication for companies and LLPs. The authorised signatory's DSC must be registered and valid on the portal.
• DSC token expiry. DSC tokens are typically valid for two to three years. Check the expiry date in February every year. If the DSC needs renewal, initiate it at least three weeks before 31 March — renewal involves verification time.
• Skipping witness details. The occupation field for witnesses cannot be left blank. Pre-prepare a standard template with two pre-approved witnesses (a director, a CA, a senior employee) and their details.
• Not downloading the LUT certificate. The ARN is proof of submission, but the LUT certificate PDF is what everyone asks for. Download it immediately; do not rely on retrieving it later.
• Assuming last year's LUT covers this year. It does not. Each FY is a fresh filing.
• Not tracking forex realisation by invoice. Filing the LUT correctly but missing the FEMA deadline is the single biggest source of post-LUT interest liability.
• Raising export invoices at an unregistered GSTIN. The LUT must be filed at the GSTIN from which the export invoice is issued. A Mumbai branch cannot rely on the Delhi head office's LUT.

Key Takeaways

• File LUT in Form GST RFD-11 on gst.gov.in by 31 March 2026 for FY 2026-27 — every export invoice raised after 1 April without a filed LUT is an IGST liability waiting to be discovered.
• Any registered exporter is eligible unless formally prosecuted for GST evasion exceeding Rs. 2.50 crore. There is no turnover floor and no status-holder requirement post Notification No. 37/2017-CT.
• DSC is mandatory for companies and LLPs. Check DSC expiry by 15 February and renew early. EVC is only available to proprietors and partnerships.
• Post-filing obligations are legally binding: goods must be exported within three months of the invoice and forex must be realised within the FEMA-prescribed period — breach triggers IGST plus 18% interest backdated to the invoice date.
• Multi-GSTIN entities must file a separate LUT for every GSTIN. Build a centralised compliance calendar with one responsible person named per registration.
• Maintain an export realisation register tracking invoice date and forex receipt date for every export invoice. Flag any invoice at the seven-month mark for banker escalation or RBI extension application.
• Download and archive the LUT certificate PDF every year. Label it by GSTIN and FY. It will be requested during refund processing, GST audits, banker due diligence, and DGFT verification throughout the year.