LUT in GST: How to File, Validity and Last Date | BuildWright
LUT in GST for Exporters: Who Files It, When, and What Happens Without One
8 min read
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Exporting services? We file your LUT and set up the export paperwork.
A Letter of Undertaking, or LUT, is the form a registered exporter files so that goods or services can be exported without paying IGST. You furnish it in Form GST RFD-11 on the GST portal, it lasts for one financial year, and rule 96A(1) of the CGST Rules wants it in place before the export. If you export without one, IGST applies to the invoice and you claim it back through a refund.
Key takeaway
No rule sets a calendar 'last date' for the LUT. Rule 96A(1) says it is furnished prior to export, and the Board's circular says it is valid for the financial year in which it is furnished. In practice that means one filing each April and a fresh one for the next year. If you are reading this mid-year with no LUT on file, file it before your next export invoice.
What an LUT does
Exporting goods or services is a zero-rated supply (section 16(1)(a) of the IGST Act). A registered person making one can supply without paying IGST and claim a refund of unutilised input tax credit, under a bond or a Letter of Undertaking (section 16(3)). By signing the LUT you bind yourself to pay the tax with interest under section 50(1) if the export does not complete within the times in rule 96A(1). A bond is the alternative. The Board's circular says persons who have been prosecuted for evasion above ₹250 lakh furnish a bond instead, with a bank guarantee of 15% of the bond amount (Circular 8/8/2017-GST, paragraph 2(f)).
Older articles say section 16(3) gives you a free choice between exporting under an LUT and paying IGST for a refund. That wording was replaced from 1 October 2023. Section 16(3) now speaks of the LUT route, and paying IGST and claiming it back is open for the classes the Government notifies under section 16(4). Notification 01/2023-Integrated Tax notifies every service, and every good except the items in its table: pan masala, tobacco products and some mint oils.
Who can file
Any registered person who intends to supply goods or services for export without paying IGST can furnish an LUT in place of a bond. The one exclusion is a person who has been prosecuted for an offence under the CGST Act, the IGST Act or an earlier law where the tax evaded exceeds ₹250 lakh (Notification 37/2017-Central Tax). The department accepts your self-declaration on that point and may verify it later (Circular 8/8/2017-GST, paragraph 2(d)). Rule 96A(6) extends the same route to zero-rated supplies to an SEZ developer or unit.
This article is general information, not legal advice. If you need advice for your specific situation, contact BuildWright directly.
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For services, the supply has to be an export of services as section 2(6) of the IGST Act defines it. All five of these must hold:
You, the supplier, are located in India.
The recipient is located outside India.
The place of supply is outside India.
You receive the payment in convertible foreign exchange, or in Indian rupees where the RBI permits.
You and the recipient are not merely establishments of one person.
An LUT is filed by a registered person, so you need a GSTIN first. If you are a freelancer working out whether you need one, start at the freelancer guides.
When to file it, and the last date
Rule 96A(1) says the LUT is furnished prior to export. The rule sets no date within the year. Validity is the other half: the LUT is valid for the whole financial year in which it is furnished (Circular 8/8/2017-GST, paragraph 2(b)), and the portal marks it Expired at the end of that year. An LUT for 2026-27 therefore stops at the end of 31 March 2027, and the next one has to be in place before your first export invoice of 2027-28.
You will see 31 March quoted online as the last date. We found it in no rule, notification or circular. What the rule gives you is an order of events: the LUT first, the export after. An LUT furnished in October covers exports made after you furnish it. Rule 96A(1) asks for it before the export, so it does not cover invoices you have already issued.
How to file on the GST portal
Log in at gst.gov.in and go to Services, then User Services, then Furnish Letter of Undertaking (LUT).
Form GST RFD-11 opens. Choose the financial year the LUT is for.
If you furnished an LUT manually and it was approved, you can upload it as a PDF or JPEG of up to 2 MB. This is optional.
Tick the declaration boxes.
Enter the names and addresses of two independent and reliable witnesses, and the place of filing.
Choose the authorised signatory, preview the form, and sign with DSC or EVC.
The portal gives you an ARN and sends it to your registered email and mobile number. Download the acknowledgement.
Notification 37/2017 says the LUT is executed by the working partner, the managing director, the company secretary or the proprietor, or by a person they have authorised. You can save a draft on the portal and come back to it (My Saved Applications).
After you file
The portal shows a status: Submitted, Pending for Clarification, Pending for Order, Approved, Rejected, Deemed Approved or Expired. The Board's circular says an LUT should be accepted within three working days of receipt with the self-declaration, and is deemed accepted if it is not (paragraph 2(e)). The portal does the same: it shows Deemed Approved when the officer takes no action in three working days. If the officer asks for clarification, you have 15 working days to reply. A tax officer can also disable LUT filing for a taxpayer; you are told by SMS and email and have to ask the officer to enable it again.
What the LUT binds you to
The LUT binds you to pay the tax with interest if the export does not complete in time. Rule 96A(1) sets two clocks:
Goods: 15 days after three months from the date of the export invoice, if the goods have not been exported. The Commissioner can allow a longer period.
Services: 15 days after one year from the date of the export invoice, or after the period the Foreign Exchange Management Act allows including any RBI extension, whichever is later, if you have not received payment in convertible foreign exchange or in Indian rupees where the RBI permits. The Commissioner can allow a further period.
If you miss the payment, the facility to export without IGST is withdrawn at once and the amount is recovered under section 79. It is restored as soon as you pay what is due (rule 96A(3) and (4); clause (iii) of Notification 37/2017 applies the same withdrawal and restoration to both limbs). An exporter of services who is waiting on a slow foreign client should watch the services clock, because it runs from the invoice date.
Exporting without an LUT
Rule 96A(1) makes the LUT a condition of exporting without IGST. An export is an inter-State supply on which IGST is levied (sections 5(1) and 7(5)(a) of the IGST Act), and the LUT is what lets you supply it without paying that tax. With none on file, the no-IGST route is not open to you for that invoice, and the invoice has to carry IGST. You can claim the tax back, as the next section explains.
If you have already billed foreign clients without IGST and without an LUT, treat it as a problem to fix now. We found no circular that lets a later LUT cover earlier invoices. The papers to gather are the invoices, the payment records and the date you filed. Talk to us about the steps; we prepare the LUT and the related filings.
If you paid IGST: the refund route
IGST paid on a zero-rated export can be claimed back. For services, the application goes in Form GST RFD-01 on the portal and is dealt with under rule 89 (rule 96(9)). For goods, the shipping bill is deemed to be the refund application once the conditions in rule 96(1) are met, including a valid GSTR-3B.
The time limit is two years from the relevant date (section 54(1) of the CGST Act). For services, the relevant date is the date you receive payment in convertible foreign exchange or in rupees where the RBI permits, if the service was complete before the payment arrived. If the client paid in advance, it is the date of the invoice (section 54, Explanation (2)(c)). You cannot take both routes on the same supply: section 54(3) bars a refund of input tax credit where the supplier claims a refund of the IGST paid on the same supplies. Paying first also means you fund the tax until the refund arrives, which an LUT avoids.
The RBI side
The LUT is a GST step. Separately, the RBI's Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026, ask an exporter of services to file an Export Declaration Form within 30 days from the end of the month in which the invoice was raised (regulation 3(2)). Whether that applies to you is what the EDF checker answers. If you ship goods, the IEC application is a separate registration we file.
Yes. It is valid for the financial year in which you furnish it, and the portal marks it Expired at the end of that year.
Note
Rules, notifications and the GST portal guide read on 23 October 2026. The 31 March 'last date' that circulates online is not in any of them.