File Form RFD-11 for FY 2026-27 to supply exports and SEZ transactions under LUT without paying IGST — eligibility, portal process, renewal and pitfalls.
Form RFD-11 is the GST world's quietest workhorse for exporters. Every exporter of goods or services and every supplier to an SEZ unit or developer must either pay IGST on the supply and claim refund, or supply without payment of tax under a Letter of Undertaking. For FY 2026-27 the LUT route remains the cleaner option — no cash outflow, no refund cycle — provided the eligibility conditions are met and Form RFD-11 is filed on time.
Who Needs to File RFD-11
- Exporters of goods to destinations outside India
- Exporters of services where the place of supply is outside India and payment is received in convertible foreign exchange or INR as permitted by RBI
- Suppliers to Special Economic Zone units or SEZ developers
- Persons claiming the zero-rated supply benefit under section 16 of the IGST Act without payment of tax
Eligibility to File LUT Instead of a Bond
Any registered person eligible to supply goods or services under bond or LUT can file an LUT, provided they have not been prosecuted for tax evasion of an amount exceeding the threshold specified in the relevant CBIC notification. The earlier turnover and clean record conditions have been substantially relaxed, so almost every regular exporter today qualifies for LUT and does not need to furnish a bank guarantee.
Filing Process on the GST Portal
- Log in to the GST portal with the GSTIN and password
- Go to Services → User Services → Furnish Letter of Undertaking
- Select the financial year for which the LUT is being filed
- Upload the previous year's LUT, if any, and the supporting documents
- Fill the name, address and occupation of two independent witnesses
- Sign with DSC or EVC of the authorised signatory and submit; download the acknowledgement and ARN
Validity and Renewal
An LUT in Form RFD-11 is valid for one financial year. A fresh LUT must be filed for every new financial year, ideally on or before 1 April, so that exports made on day one are covered. If an exporter raises a zero-rated invoice before the LUT for the year is filed, that supply is exposed to IGST and the cleanest fix is to pay tax, claim refund and tighten the calendar going forward.
Consequences of Not Filing or Breach
- Zero-rated supplies become taxable at the applicable IGST rate, with interest from the date of invoice
- Departmental notices for short payment and recovery of tax along with penalty
- Loss of the LUT facility — the exporter may be required to operate under bond with bank guarantee
- Delay in refunds because the underlying exports are not classified as bond/LUT supplies
Conclusion
RFD-11 is one of those forms that is trivial in effort and expensive in omission. Make the LUT filing an April ritual, retain the ARN with the export documentation, and brief the sales team that every zero-rated invoice from day one needs to reference a valid LUT number. Done routinely, it keeps working capital free and refunds uncomplicated.
