GST LUT Form RFD-11: Eligibility, Rules & Filing

TL;DR

A Letter of Undertaking (LUT) in Form GST RFD-11 lets Indian exporters clear zero-rated shipments without paying IGST upfront. Under Rule 96A, you must submit the LUT online on the GST portal before any export for the financial year. The LUT is valid for one full financial year. If goods do not leave India within 3 months, you must pay the IGST liability within 15 days. You also pay interest at 18% per year.

Quick Answer: What is a Letter of Undertaking (LUT) in GST?

Under Section 16 of the IGST Act, exports of goods and services are classified as zero-rated supplies. Supplies to SEZ developers and units are also zero-rated.

Exporters can fulfil zero-rated shipments through two routes.

1. Supply under Letter of Undertaking (LUT): Export goods or services without paying IGST at the time of clearance. You protect your operating cash flow. Later you apply for a refund of accumulated unutilised Input Tax Credit (ITC) under Rule 89.
2. Supply on payment of IGST: Pay the full output IGST from your pocket or through electronic ledgers. Then claim a customs refund via ICEGATE after the shipping bills are processed.

For industrial clusters across Gujarat, the LUT route is standard practice. This includes ceramic manufacturers in Morbi, textile mills in Surat, brass component foundries in Jamnagar, and chemical plants in Ankleshwar and Dahej. Paying 12% to 18% tax on export consignments locks up significant cash in customs refund cycles.

eCommerce sellers: If you export goods internationally through Amazon FBA, your own D2C channel, or a combination, the GST LUT (Form RFD-11) lets you ship without paying IGST upfront. Later you claim a refund of accumulated input tax credit. Without an LUT, every export consignment locks away 12–18% of your input costs as irrecoverable tax. See FinTax24’s eCommerce GST Hub for the LUT filing guide, export GST refund process, and ITC management for international e-commerce sellers.

[Registered Exporter] ── (Files Form RFD-11 Online) ──> [GST Portal Approval]
         │                                                        │
         │                                                        ▼
         │                                          [LUT Acknowledgement Received]
         ▼                                                        │
[Export Goods / Services]                                          │
         │                                                        │
         │◄─── (No IGST paid on export) ───────────────────────┘
         │
         ▼
[File GSTR-1 / GSTR-3B Monthly]
         │
         ▼
[Claim ITC Refund Under Rule 89 / Rule 96B]

Who Can File a GST LUT?

Eligibility Criteria (Rule 96A)

To file a GST LUT in Form RFD-11, you must meet all of the following:

1. You must be a registered person under GST.
2. You must have a valid GSTIN (Goods and Services Tax Identification Number).
3. You must have filed all applicable GST returns (GSTR-1 and GSTR-3B) up to the date of filing the LUT.
4. You must not have any outstanding tax liability (including interest, penalty, or late fees).
5. You must not be under investigation or prosecution under the CGST Act or IGST Act.

Who Cannot File an LUT?

The following taxpayers cannot use the LUT route:

• Taxpayers under investigation for GST evasion or fraud.
• Taxpayers who have not filed their GST returns.
• Taxpayers with outstanding tax demands.
• Exporters of goods that are specifically notified as ineligible for the LUT route.

How to File Form GST RFD-11 on the GST Portal

Step 1: Check Eligibility

Before filing the LUT, ensure all your GST returns are filed up to date. Log in to the GST portal and check your return filing status under “Returns Dashboard”. Resolve any pending GSTR-1 or GSTR-3B mismatches before proceeding.

Step 2: Navigate to LUT Filing

1. Log in to the GST portal at gst.gov.in.
2. Navigate to Services → Registration → Letter of Undertaking (LUT).
3. Select the financial year for which the LUT is being filed.
4. Tick the declaration checkbox confirming eligibility.

Step 3: Fill in Form RFD-11 Details

The form requires:

• GSTIN (auto-populated).
• Name of the registered person (auto-populated).
• Details of authorised signatory (name, designation, and address).
• Details of the bank account linked to the GSTIN.
• A declaration that all GST returns have been filed.

Step 4: Submit with Digital Signature or EVC

Submit the completed Form RFD-11 using a Digital Signature Certificate (DSC) for companies and LLPs. Individuals and proprietors can use Electronic Verification Code (EVC) via Aadhaar OTP.

Upon successful submission, an ARN (Application Reference Number) is generated. The LUT is deemed accepted if no intimation of rejection is issued within 3 working days.

Step 5: Download the LUT Acknowledgement

Once accepted, download the LUT copy from the portal. Store it securely. You will need it for customs clearance and for claiming export refunds.

Key Rules After Filing the LUT

Rule 1: Export Within 3 Months

If goods are exported, they must leave India within 3 months of the date of the invoice. If goods do not leave within 3 months, the exporter must pay the applicable IGST. The payment must be made within 15 days of the expiry of the 3-month period.

Rule 2: Monthly Return Filing

Even with an LUT, you must file GSTR-1 and GSTR-3B every month. Export sales are reported as zero-rated supplies in GSTR-1. No IGST is payable on these supplies.

Rule 3: Interest on Late Payment

If you fail to pay IGST within the 15-day window (when goods do not leave India), interest at 18% per annum is charged. The interest is calculated from the date of the invoice to the date of actual payment.

Rule 4: ITC Refund Claim

After exporting, you can claim a refund of accumulated unutilised ITC. This is filed using Form GST RFD-01. The refund is processed under Rule 89 (for LUT exports) or Rule 96B (for export through customs route).

Rule 5: LUT Renewal Each Financial Year

The LUT is valid for one financial year only. You must file a fresh LUT at the start of each new financial year. The previous year’s LUT does not carry forward.

GST LUT vs Bond: What is the Difference?

Before the GST era, exporters used a “bond” format. This was a physical document with bank guarantee or fixed deposit receipt as security. Under GST, the LUT has replaced the bond. No security deposit or bank guarantee is required for filing an LUT.

The LUT is a simple online declaration. It carries the same legal standing as the old bond. If an exporter defaults (fails to export or pay IGST when required), the GST officer can recover the amount as a debt.

Export Refund: LUT Route vs Customs Refund Route

Feature	LUT Route (Rule 89)	Customs Refund Route (Rule 96B)
IGST paid at export	No	Yes (from pocket or credit ledger)
Refund type	ITC accumulation refund	Customs IGST refund
Refund timeline	Typically 60–90 days	Typically 30–60 days
Documentation	GSTR-1, GSTR-3B, shipping bills	Shipping bills,银行凭证, LUT copy
Interest on default	18% per annum	Not applicable

Common Mistakes to Avoid

1. Filing LUT Without Filing Returns: The portal will reject your LUT if you have pending GSTR-1 or GSTR-3B returns. File all returns first.
2. Not Renewing the LUT Each Year: The LUT lapses at the end of the financial year. File a fresh LUT at the start of each new financial year.
3. Exporting After LUT Expiry but Before Renewal: If your LUT has expired and you have not yet filed the new one, any export during this gap attracts IGST. Plan your LUT renewal in advance.
4. Failing to Report Export in GSTR-1: Even though no IGST is paid, export sales must be reported in GSTR-1 as zero-rated supplies. Failure to report exports triggers notices.
5. Not Keeping LUT Copy for Customs: The LUT acknowledgement must be submitted to customs at the port of export. Without it, customs may not allow export under the LUT bond route.

Frequently Asked Questions

Can a new exporter file an LUT?

Yes. A newly registered GST taxpayer can file an LUT as long as they meet the eligibility criteria. There is no minimum period of operation required.

Do I need a bank guarantee to file an LUT?

No. The GST LUT does not require a bank guarantee or security deposit. It is a simple online declaration.

Can a composition taxpayer file an LUT?

No. Composition taxpayers cannot export under the LUT route. They must pay IGST on export supplies and then claim a refund.

What happens if I export goods but the LUT has expired?

If your LUT has expired and you export goods, the export is treated as a regular taxable supply. IGST is payable at the applicable rate. You must pay the IGST and then claim a refund.

Can an LUT be filed for exports to SEZ units?

Yes. Supplies to SEZ developers and SEZ units are zero-rated. An LUT can be filed to cover these supplies without paying IGST.

How long does it take for an LUT to be accepted?

The GST portal issues an ARN immediately upon submission. If the LUT is not rejected within 3 working days, it is deemed accepted. No separate approval intimation is sent.

Is the LUT valid for both goods and services exports?

Yes. The GST LUT in Form RFD-11 covers both goods and services exports. It also covers supplies to SEZ developers and units.

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Need Help with GST LUT Filing?

FinTax24 assists Gujarat exporters across Morbi, Surat, Jamnagar, Vadodara, and Ankleshwar with LUT filing, annual renewal, and export ITC refund claims. We ensure your LUT is filed on time, your exports are reported correctly, and your refund claims are processed without delays. Contact us to get your export operations running on the LUT route.