LUT filing for service exporters: steps, validity and what comes next

File a Letter of Undertaking (LUT) in Form GST RFD-11 before exporting taxable services without paying IGST. This route is for eligible GST-registered exporters. A refund of accumulated input tax credit is a separate application in RFD-01. CBIC Circular 125/44/2019-GST, paragraphs 3 and 44.

Already have an LUT for the correct year? Go to what to prepare after filing.

Can a new freelancer or software business file an LUT?

Yes, if GST-registered and eligible. You do not need a minimum export turnover, ₹1 crore of foreign receipts or a previous year of exports. Those older eligibility tests were replaced. The exclusion concerns people prosecuted for offences under the specified tax laws where the tax evaded exceeds ₹2.5 crore; a bond is required where that exclusion applies. CBIC Circular 8/8/2017-GST, paragraph 2(a) and (f).

An LUT does not establish that every foreign payment qualifies as an export of services. Check the underlying customer, supply and payment arrangement in the foreign-client invoice guide.

Which financial year should I select?

Select the year covering the exports. An LUT is valid for a financial year, ending on 31 March, rather than for 12 months from filing. A fresh LUT is needed for the next year. CBIC Circular 8/8/2017-GST, paragraph 2(b).

For example, a business starting exports in September 2026 selects 2026–27. That year’s LUT ends on 31 March 2027. It prepares the 2027–28 LUT before its first export in the new year. A business starting midway through a year can furnish its LUT then; 31 March is not a once-a-year application window.

How do I file RFD-11 on the GST portal?

Keep your authorised signatory’s signing access and two witnesses’ details ready. The GST portal’s LUT instructions describe this process:

1. Log in at gst.gov.in for the correct registration. Open Services → User Services → Furnish Letter of Undertaking (LUT).
2. Check the prefilled GSTIN and legal name. Select the financial year.
3. If recording a previously approved manual LUT, use the previous-LUT upload field. This is optional; a first-time applicant does not need an earlier LUT. The documented upload limit is one file up to 2 MB.
4. Read and accept the undertaking declarations.
5. Enter the names, addresses and occupations of two independent and reliable witnesses.
6. Complete the verification and select the authorised signatory. Preview the application and correct errors before signing.
7. File using the applicable DSC or EVC signing option. Saving a draft or preview PDF does not complete filing.
8. Download the acknowledgement carrying the Application Reference Number (ARN).

To find a filed LUT later, use Services → User Services → View My Submitted LUTs. Keep the acknowledgement and filed form together, with the financial year in their filenames.

Does the ARN mean my LUT or refund is approved?

For an online LUT, the ARN acknowledgement records acceptance. Save it with the filed RFD-11. CBIC says physical submission to the jurisdictional office is unnecessary for acceptance; eligibility can be examined subsequently. CBIC Circular 40/14/2018-GST.

Your later RFD-01 refund application receives its own ARN and undergoes separate scrutiny. GST portal: refund application and processing.

I exported before filing the LUT. What now?

Gather the affected invoices, dates, payment evidence and the LUT actually furnished. Ask your preparer to address the delay with the jurisdictional officer. CBIC allows delay to be condoned and LUT treatment to be permitted retrospectively where qualifying exports are established, depending on the facts. A late acknowledgement alone does not document that consideration. CBIC Circular 125/44/2019-GST, paragraph 44.

Court rulings (checked 22 October 2026): the Karnataka High Court has held that not furnishing an LUT before export “is not an incurable defect”, and sent a goods exporter’s rejected refund back for reconsideration in the light of CBIC’s condonation guidance. Prime Perfumery Works, 2 December 2025. It followed that ruling for a demand on an export of services confirmed only because no LUT had been filed, and directed the officer to let the exporter place the LUT on record. Nuvteq Solutions, 10 June 2026. In both cases the court ordered reconsideration; it did not decide that the refund or the exemption was due. Abhishek Raja Ram shared the Prime Perfumery ruling on X.

Before accepting a “late LUT” objection, compare the LUT’s date with the invoice dates in the claim. The Delhi High Court set aside a refund rejection made on that ground where the LUT was dated before every shipping bill in the claim period. Alkesh Tacker HUF, 12 August 2025.

What if the overseas customer has not paid?

Track receipt dates separately from the LUT’s financial-year expiry. Under the amended Rule 96A(1)(b), the service-payment period is the later of one year from the export invoice or the period allowed under FEMA, including an RBI-permitted extension. The Commissioner may allow a further period. If qualifying payment has not arrived by the applicable deadline, the undertaking requires tax and applicable interest to be paid within the following 15 days. Notification 12/2024-Central Tax, clause 20(i).

From 1 October 2026, FEMA allows nine months from the invoice date to receive payment for services, or twelve months if the invoice is raised or settled in rupees. For invoices from that date, the one-year period is therefore normally the later one, unless realisation is extended beyond a year (checked 22 October 2026). See the Export Declaration Form for service exports.

Keep evidence of any extension with the invoice. Do not assume renewing the LUT extends an unpaid invoice’s deadline. For receipt records and invoice matching, use the FIRC/BRC guide.

LUT filed: what do I prepare for the refund?

Build the claim around these questions:

Question to resolve	Record or next guide
Which exports and receipts belong to this claim?	Export invoice register and Statement 3 worked example
Can each receipt be traced to the invoices it settles?	Bank certificates, payment reports and FIRC/BRC reconciliation
Which purchase credits qualify, and which are excluded?	Purchase register, returns and Annexure B worked example
How much can I claim?	Refund calculation, including a claim larger than turnover
What goes into the application package?	What an RFD-01 refund claim contains

Use the refund preparation checklist to identify which records you still need.