GST LUT (Form RFD-11) — Export Without Paying IGST, and What Happens If You Miss It

1The two routes for exporting under GST

A zero-rated supply — an export of goods or services, or a supply to a Special Economic Zone — can be made in one of two ways.

Route one: furnish a Letter of Undertaking and export without paying IGST at all. Nothing leaves your bank account and there is nothing to reclaim.

Route two: pay IGST on the export and then claim a refund of it. You get the money back, but only after the refund is processed, and in the meantime it is the government holding your cash rather than you.

Both routes reach the same place. Only the first one gets there without lending the exchequer an interest-free advance, which is why virtually every regular exporter files an LUT.

2What the LUT actually is

An LUT is a declaration, filed in Form GST RFD-11 on the GST portal, in which you undertake to fulfil the conditions attached to exporting without payment of tax — chiefly that the goods or services will actually be exported, and that if you fail to do so you will pay the tax with interest.

It is not a licence, an approval or a favour. It is a promise you make, filed once a year, that turns the zero-rating from a refund into an exemption at source.

3Who can file — and who cannot

Any registered person exporting goods or services out of India, or supplying to an SEZ developer or unit, may furnish an LUT. There is no turnover threshold and no minimum export volume.

There is one significant bar. A person who has been prosecuted for tax evasion of more than ₹2.5 crore under the CGST Act, the IGST Act or any other existing law cannot file an LUT. Such an exporter must instead furnish a bond with a bank guarantee, which is exactly as inconvenient as it sounds and is the practical reason the bar bites.

4The deadline that catches people every year

An LUT is valid for one financial year and no longer. The LUT you filed for FY 2025-26 expired on 31 March 2026 and does not carry into the new year, however faithfully you have exported under it.

The LUT for FY 2026-27 had to be filed by 31 March 2026 — before the year it covers begins, not during it. The GST portal opens filing for the coming year in advance precisely so this can be done ahead of time.

The practical rule is simpler than the dates: file the new LUT before you raise your first export invoice of the year. If your first April invoice goes out before the LUT is on record, that export was not covered.

5What happens if you miss it

Nothing dramatic happens on the portal — and that is the trap. There is no penalty for filing late and no notice arrives. The consequence is purely commercial.

Without a valid LUT on the date of the export, that supply cannot be made without payment of IGST. You must pay the IGST and then claim it back as a refund, which means preparing the refund application, waiting for it to be processed, and financing the gap yourself.

For an exporter running on thin margins and monthly shipments, a forgotten form turns into a lakhs-sized hole in working capital for a quarter. The cost of the mistake is entirely a cash-flow cost, and entirely avoidable.

If you have already missed it, file the LUT now. It cannot retrospectively cover invoices you have already raised, but it stops the bleeding from the next one onward.

6Filing it — what the process looks like

• Log in to the GST portal and go to Services → User Services → Furnish Letter of Undertaking (RFD-11)
• Select the financial year the LUT is for — check this carefully, since filing for the wrong year is the most common slip
• Accept the undertakings on the form (export within the prescribed time, and pay tax with interest if you fail)
• Provide the details of two independent witnesses — name, occupation and address
• Sign with DSC or EVC and submit
• Save the acknowledgement with its ARN — this is your proof that the LUT was on record before the invoice date

7After filing — the part people forget

• Quote the LUT and its ARN on your export invoices, along with a note that the supply is made without payment of IGST under LUT
• Report the exports correctly in GSTR-1 under the exports table, marking them as without payment of tax
• Keep shipping bills and, for services, the FIRC or bank realisation evidence — the LUT is an undertaking to actually export, and proof matters if it is questioned
• Diarise next year's LUT for March, not April
• Remember the LUT is per GSTIN — if you have registrations in several states, each one needs its own

8Common misunderstandings

An LUT is often described as something you apply for and wait to be granted. You do not. It is furnished, and it takes effect on filing; there is no approval step to wait out.

It is also sometimes assumed to cover all your exports forever once filed. It covers one financial year, for one GSTIN, and lapses on 31 March regardless of how well you have complied.

Finally, an LUT does not make your inputs tax-free. You continue to pay GST on your purchases; the LUT only stops IGST being charged on the export itself. The accumulated input credit is separately refundable under the zero-rated supply provisions, and that refund claim is a distinct process from the LUT.