LUT for Export Without GST: How to File RFD-11 (2026)

Quick Summary

A Letter of Undertaking (LUT) lets a registered exporter ship goods or supply services outside India without paying IGST upfront. You file it once a year on the GST portal in Form RFD-11, and the approval is instant. This guide walks through eligibility, the exact portal steps, the conditions you must honour after filing, and the common mistakes that block submissions.

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What You'll Learn

How to file LUT in Form RFD-11 on the GST portal in under 15 minutes
What the eligibility rules, validity period, and witness requirements are
How to avoid the conditions that turn a tax-free export into an 18% interest demand

What is LUT for Export Without GST?

Exports from India are zero-rated under GST. That gives you two options as an exporter: pay IGST on the export invoice and claim a refund later, or file a Letter of Undertaking and ship without paying any IGST in the first place.

The LUT is a self-declaration in Form GST RFD-11, filed under Rule 96A of the CGST Rules. By signing it, you promise to complete the export within the prescribed timeline and to pay the IGST plus interest if you do not. In return, the portal lets you raise zero-tax export invoices for the rest of the financial year.

For most MSME exporters, LUT is the obvious choice. Paying IGST and waiting weeks or months for the refund locks up working capital that a small business cannot spare.

Who Needs to File an LUT?

You should file an LUT if you are a GST-registered taxpayer who:

Exports goods outside India
Supplies services to a recipient outside India and gets paid in foreign exchange
Supplies goods or services to a Special Economic Zone (SEZ) developer or unit

If you do any of the above and want to avoid blocking cash in IGST, file the LUT before you raise your first export invoice of the financial year.

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One LUT per Financial Year

An LUT is valid only for the financial year in which it is filed. It expires on 31 March every year, regardless of when you filed it. Mark a calendar reminder for early April so your next year's LUT is in place before your first April export invoice.

Eligibility: Who Can File LUT

The eligibility bar is deliberately wide so that almost every exporter qualifies. You can file LUT if you are any registered person under GST who intends to make a zero-rated supply.

There is one disqualifier worth knowing. Per the GST portal user guide, a taxpayer who has been prosecuted for tax evasion of ₹2.5 crore or more under the CGST Act or the IGST Act is not eligible to file LUT. Such taxpayers must furnish a bank guarantee bond instead.

For practical purposes, a first-time MSME exporter with a clean compliance history will not run into this restriction.

LUT vs Paying IGST and Claiming Refund

Both routes get you to the same end state: zero net GST on the export. The difference is timing and cash flow.

Factor	With LUT (RFD-11)	Pay IGST + Refund
Tax paid on export invoice	Zero	IGST at full rate
Working capital impact	None	Cash blocked until refund
Refund processing time	Not applicable	Typically 60+ days
Compliance burden	One filing per year	Refund claim per consignment
Best for	Most exporters, especially MSMEs	Exporters with refund automation in place

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Hypothetical Example

A textile exporter in Surat ships ₹50 lakh of fabric to a UAE buyer in May. Under the pay-and-refund route, the exporter pays ₹9 lakh as IGST upfront (assuming 18%) and waits for the refund. Under LUT, the same export goes out with zero IGST, and the ₹9 lakh stays in the business for procurement, salaries, or the next order.

Prerequisites for Filing LUT

Before you log in to the GST portal, keep these ready:

Active GST registration with valid GSTIN credentials
Digital Signature Certificate (DSC) for companies and LLPs (mandatory), or registered mobile and email for EVC verification (allowed for proprietorships and partnerships)
Two independent witnesses: name, address, and occupation of each
Authorised signatory details as registered with GST (proprietor, working partner, managing director, company secretary, or any duly authorised representative)
PDF or JPEG of any prior LUT filed manually in earlier years (only if applicable; max 2 MB)

The witnesses do not need to be GST-registered themselves. Two trusted contacts (a CA, a colleague, or a family member) work.

How to File LUT on the GST Portal: Step-by-Step

The full process takes about 10 to 15 minutes if your details are ready.

Step 1: Log in to the GST Portal

Go to www.gst.gov.in and log in with your GSTIN, username, and password.

Step 2: Navigate to the LUT Form

From the dashboard, follow this path: Services > User Services > Furnish Letter of Undertaking (LUT).

Step 3: Select the Financial Year

On the LUT form, choose the relevant year from the LUT Applied for Financial Year dropdown. For exports between 1 April 2026 and 31 March 2027, select 2026-27.

If you filed LUT manually in any previous period, upload the scanned copy here. Most exporters can skip this step.

Step 4: Tick the Self-Declaration Checkboxes

Three checkboxes appear, each capturing a binding condition. By ticking them you agree to:

Complete the export of goods within three months from the date of the export invoice, or such further period as the Commissioner may allow
Realise foreign exchange for export of services within one year from the date of the invoice
Comply with all GST law provisions related to zero-rated supplies, and pay IGST plus interest under Section 50 of the CGST Act if you fail to meet conditions 1 or 2

These commitments are not optional. The interest rate for non-compliance is 18% per annum on the unpaid IGST.

Step 5: Fill Witness Details

Enter the name, address, and occupation of two independent witnesses. The fields are simple text inputs. Keep the details consistent with what your witnesses can confirm if asked later.

Step 6: Enter the Place of Filing and Preview

Type the place of filing (typically your principal place of business as registered under GST). Click PREVIEW to download a draft PDF and verify every field before signing.

Step 7: Sign and Submit

Choose your authorised signatory from the dropdown, then submit using one of:

FILE WITH DSC: required for companies and LLPs. Plug in your DSC token, click SIGN, and confirm.
FILE WITH EVC: enter the OTP sent to the registered mobile and email of the authorised signatory.

Step 8: Save the ARN

On successful filing, the portal generates an Application Reference Number (ARN) and shows a confirmation screen. Download the acknowledgement PDF and save the ARN in your records. This is the proof you will reference if any future return or refund query asks whether your LUT is in place.

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Golden Rule

LUT approval is automatic and instant. There is no officer review, no waiting period, and no fee. The moment the ARN appears, you can raise zero-IGST export invoices for the rest of the financial year.

What Happens If You Breach the Conditions?

The LUT is a promise. If you fail to keep it, the protection collapses.

Goods not exported within 3 months of the invoice date: you must pay the IGST that would have applied, plus 18% annual interest from the invoice date until payment
Services exported but foreign exchange not realised within 1 year: same consequence, meaning IGST plus interest
Repeated breaches: the department can withdraw your LUT facility and require a bank guarantee bond for future zero-rated supplies

If a genuine reason delays the export (buyer rejection, force majeure, port disruption), you can apply to the jurisdictional Commissioner for an extension before the three-month window closes.

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The 3-Month Clock Starts at Invoice, Not Order

Do not measure the export window from the buyer's purchase order or the booking date. The clock starts the day you raise the GST export invoice. For long-lead-time custom orders, raise the invoice close to the dispatch date — not at order confirmation.

Common Mistakes That Block LUT Filing

A few simple errors cause most failed submissions.

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Filing Errors to Avoid

Wrong financial year selection: filing FY 2025-26 in May 2026 makes the LUT immediately invalid for current exports. Always pick the year covering today's date.

Authorised signatory mismatch: the signatory in the dropdown must be the one whose DSC or registered mobile you are using. Update the Authorised Signatory under My Profile before filing if it has changed.

Missing witness fields: both witness rows must be fully filled. Blank occupation or partial address triggers a validation error on submit.

DSC not registered on portal: a fresh DSC must be registered under Register / Update DSC before it can sign an LUT. Doing this on the same day as filing avoids token mismatch.

Trying to use last year's LUT: an LUT from FY 2025-26 cannot cover an export invoice raised on or after 1 April 2026. File the new year's LUT first.

Frequently Asked Questions

QIs there any fee for filing LUT on the GST portal?

No. Filing Form RFD-11 on the GST portal is completely free. There is no government fee, processing charge, or stamp duty. If a consultant offers to file LUT for you, the fee is purely their service charge. You can do it yourself in 10 to 15 minutes.

QCan I file LUT before getting my IEC?

Yes, technically the LUT only requires GST registration. But for actual exports of goods you need an Import Export Code (IEC) from DGFT. It makes sense to apply for IEC and LUT around the same time so both are in place before your first export invoice.

QDo I need a fresh LUT every year, even if I had no exports?

Yes. The LUT is valid only for the financial year in which it is filed. Even if you did not export anything in the past year, file a new LUT for the new financial year if you intend to export. There is no penalty for filing and not using it.

QCan I revise an LUT after filing?

There is no revise option once an ARN is generated. If you spot a major error (wrong financial year, wrong authorised signatory), the practical fix is to file a fresh LUT with the correct details. The portal accepts it; the latest filing for that financial year is treated as current.

QDoes LUT cover supplies to SEZ units?

Yes. Supplies to a Special Economic Zone developer or unit are treated as zero-rated supplies under Section 16 of the IGST Act. The same LUT covers exports outside India and SEZ supplies, with no separate filing required.

QWhat if my GST registration is suspended? Can I still rely on an existing LUT?

No. A suspended or cancelled GST registration invalidates the LUT for invoices raised during the suspension period. Resolve the registration issue first, and any IGST on invoices raised while suspended will need to be paid with interest.