When do I need a GST LUT in Form RFD-11?
What a Letter of Undertaking does for zero-rated exports and SEZ supplies, who can file Form GST RFD-11, how long it lasts, and how to confirm the current position on the GST portal.
In this guide
A registered person who wants to export goods or services, or make a zero-rated supply to an SEZ, without paying integrated tax must furnish a Letter of Undertaking in Form GST RFD-11 before that supply. The GST portal files it for a chosen financial year. The facility is unavailable after a prosecution for tax evasion of ₹2.5 crore or more. File a fresh LUT each year before the first export.
What does a GST LUT do?
Exports and certain supplies to a Special Economic Zone are zero-rated under section 16 of the Integrated Goods and Services Tax Act, 2017. Zero-rated does not mean the supplier can skip every GST step. It means the supply can go out either on payment of integrated tax, with a refund later, or without payment of that tax against a bond or a Letter of Undertaking.
The LUT is the second route. It is furnished in Form GST RFD-11 before the export or the SEZ supply. Once it is in place for the financial year, the supplier invoices those supplies at a nil integrated-tax rate and keeps working capital out of a refund queue.
Who can file an LUT?
Notification 37/2017-Central Tax, issued under rule 96A of the CGST Rules, lets a registered person furnish an LUT instead of a bond, subject to one exclusion: the person must not have been prosecuted for any offence under the CGST Act, the IGST Act, or the earlier law, where the tax evaded exceeds ₹2.5 crore. The GST portal tutorial repeats that same test.
A person who fails it furnishes a bond, with a bank guarantee, in the manner the circulars describe. Everyone else who wants to export or supply to an SEZ without paying integrated tax files the LUT on the portal.
How do I file Form GST RFD-11?
The official tutorial is specific. Log in to the GST portal and open Services, User Services, Furnish Letter of Undertaking (LUT). GSTIN and legal name come from the login. The filer selects the financial year, enters two witnesses, accepts the self-declarations, and the authorised signatory signs with DSC or EVC.
| Supply | LUT needed if IGST is not paid |
|---|---|
| Export of goods outside India | Yes, before the export. |
| Export of services to a client outside India | Yes, before the supply. |
| Zero-rated supply to an SEZ | Yes, before the supply. |
After a successful filing the portal issues an ARN. The tutorial lists the statuses that follow: submitted, pending for clarification, pending for order, approved, rejected, and deemed approved where the officer does not act within three working days. Deemed approval is still an approval for that year. It is not a standing licence.
How long does LUT approval take on the portal?
LUT approval is deemed given if the jurisdictional officer does not act within three working days of the ARN, per the GST portal tutorial for Form GST RFD-11. Deemed approval covers only the financial year selected in that filing, so the next year still needs a fresh RFD-11 before the first export.
Does an LUT need a bank guarantee?
A GST LUT needs no bank guarantee. Notification 37/2017-Central Tax substitutes the LUT for the bond-plus-guarantee route under rule 96A for anyone not prosecuted for tax evasion of ₹2.5 crore or more. A person who fails that ₹2.5 crore test furnishes a bond with a bank guarantee instead, as Circular 8/8/2017-GST describes.
How long is a GST LUT valid?
The LUT is filed for one financial year. The tutorial states that the application status changes to Expired at the end of that year. Circular 8/8/2017-GST treated the LUT as valid for the year in which it is furnished. File the next year's LUT before the first April export, not after a shipment has already gone.
A change of GSTIN mid-year, including the cases the tutorial flags when a Union territory is reorganised, needs a fresh LUT on the new GSTIN for the rest of that year. The old ARN does not travel with the new number.
What if export proceeds never arrive?
Rule 96A is the reason the LUT exists. The registered person binds themselves to pay the tax due, with interest under section 50, if the goods are not exported, or if payment for the export of services is not received, within the time that rule sets. The LUT is not a waiver of that obligation.
That is also why the filing has to precede the supply. An invoice issued as a zero-rated export without an LUT (or a bond) for that year is the supplier using a route the rule has not opened.
How do I confirm LUT eligibility?
- Read section 16 for the two zero-rated routes: pay IGST and claim a refund, or export without payment against a bond or LUT.
- Open the GST portal LUT tutorial for the live filing path and the ₹2.5 crore prosecution test.
- Keep Notification 37/2017-Central Tax and Circular 8/8/2017-GST with the working file.
- File the LUT for the current financial year before the first zero-rated supply without payment of IGST.
- Watch CBIC updates if rule 96A or the form path changes.
Why do LUT exports get questioned?
- Raising the first export invoice of the year before the new LUT is filed.
- Treating last year's ARN as still valid in April.
- Assuming export of services does not need an LUT.
- Using the LUT route after a prosecution that crosses the ₹2.5 crore test, instead of a bond.
- Changing GSTIN mid-year and not filing a fresh LUT on the new number.
Where are rule 96A changes published?
LUT conditions sit in a notification and a rule, and both move through CBIC. Complied AI keeps CBIC / GST updatesin one feed so you can open the source circular behind a change instead of relying on last year's portal note. When you need the zero-rated rule itself, open section 16 next to the update.
Practical checks
Common questions
What is a GST LUT?
A Letter of Undertaking is the filing that lets a registered person export goods or services, or make a zero-rated supply to an SEZ, without paying integrated tax. It is furnished in Form GST RFD-11 on the GST portal before that supply. The other route is to pay IGST on the export and claim a refund.
Who can file an LUT instead of a bond?
Notification 37/2017-Central Tax extends the LUT facility to a registered person who intends to export without payment of integrated tax, unless that person has been prosecuted for any offence under the GST Acts or the earlier law involving tax evasion of ₹2.5 crore or more. A person who fails that test furnishes a bond instead.
How long is a GST LUT valid?
The GST portal files the LUT for a selected financial year, and the official tutorial states that the application status changes to Expired at the end of that year. File a fresh LUT for the next financial year before the first zero-rated supply in that year.
I exported in April before filing this year's LUT. Now what?
An export made without a live LUT for that financial year is outside the without-payment route in rule 96A, so the supplier is exposed to integrated tax with interest under section 50 on that supply. File Form GST RFD-11 for the current year at once, and consider treating the affected invoice on the pay-IGST-and-claim-refund route under section 16 of the IGST Act instead.
How long does the officer take to approve an LUT?
LUT approval is deemed given if the jurisdictional officer does not act within three working days of the ARN, per the GST portal tutorial for Form GST RFD-11. The tutorial also lists submitted, pending for clarification, pending for order, approved and rejected as the other statuses. Deemed approval covers only the financial year in that filing.
Do I need a bank guarantee with my GST LUT?
No bank guarantee is needed with a GST LUT. Notification 37/2017-Central Tax replaces the bond-plus-guarantee route under rule 96A for a registered person not prosecuted for tax evasion of ₹2.5 crore or more. Only a person who fails that ₹2.5 crore test furnishes a bond with a bank guarantee, as Circular 8/8/2017-GST sets out.
My GSTIN changed mid-year. Does the old LUT carry over?
No. A GST LUT is tied to the GSTIN that filed it, so a new GSTIN mid-year needs a fresh Form GST RFD-11 for the rest of that financial year. The GST portal tutorial flags this for Union territory reorganisation cases. The old ARN does not travel to the new registration number.
Is an LUT needed for export of services?
Yes, if the supply is made without payment of integrated tax. The GST portal tutorial lists export of services to a client outside India, export of goods, and a zero-rated supply to an SEZ as the cases the LUT covers. File it before the supply, not after the invoice.
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This guide is published by the Complied AI research desk. Its source list and stated position were checked against the official records shown below on 25 August 2026.
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