GST LUT Filing for Freelancers & Exporters: Form RFD-11 Online Procedure, Eligibility & Zero Tax Rules

Under India’s Goods and Services Tax (GST) architecture, exports of goods and services are classified as Zero-Rated Supplies under Section 16 of the Integrated Goods and Services Tax (IGST) Act, 2017.

To promote Indian services, software development, freelancing, and international consulting, the government provides two routes for zero-rated exports: paying IGST and subsequently claiming a refund, or exporting under a Letter of Undertaking (LUT) in Form GST RFD-11 without upfront tax payment.

Governed by Rule 96A of the Central Goods and Services Tax (CGST) Rules, 2017, filing an online Letter of Undertaking eliminates working capital blockages by allowing Indian exporters and service freelancers to invoice international clients without charging or paying GST.

1. Statutory Conditions & Time Limits Under Rule 96A

When an exporter files Form GST RFD-11, they enter into a binding statutory undertaking with the President of India agreeing to observe strict realization timelines:

Supply Type	Statutory Realization Timeline	Governing Statutory Rule
Export of Services	Receive payment in convertible foreign exchange (or INR where permitted by RBI) within one year from invoice date (or period allowed by FEMA/RBI).	Rule 96A(1)(b) of CGST Rules, 2017
Export of Goods	Ensure goods are physically exported out of India within three months from the date of the export invoice.	Rule 96A(1)(a) of CGST Rules, 2017
Failure to Realize / Export	Pay the applicable IGST along with 18% interest under Section 50(1) within 15 days of the expiry of the stipulated period.	Rule 96A(1) Proviso & Section 50

2. Eligibility Criteria for Indian Freelancers & Service Exporters

All registered taxpayers exporting goods or services are eligible to furnish an LUT unless disqualified under specific economic offense provisions:

• Mandatory GST Registration: The exporter must hold an active GSTIN. Note that for export of services (interstate supply), registration is mandatory if turnover exceeds ₹20 Lakhs (₹10 Lakhs in special category states).
• Clean Prosecution Record: The taxpayer must not have been prosecuted for any tax evasion offense where the amount involved exceeds ₹250 Lakhs (₹2.5 Crore) under the CGST Act, IGST Act, or existing laws. Exporters with such prosecution records must furnish a physical Bond with bank guarantee instead of an LUT.
• Annual Validity: An LUT submitted in Form GST RFD-11 is valid for exactly one financial year (April 1 to March 31). A fresh LUT must be filed before the commencement of each new financial year on gst.gov.in.

3. Step-by-Step Procedure to Furnish Form GST RFD-11 Online

Filing an LUT is an automated, instant procedure on the official GST portal (gst.gov.in):

1. Log In to GST Portal: Access gst.gov.in and log in with your primary authorized signatory credentials.
2. Navigate to LUT Section: Go to Services > User Services > Furnish Letter of Undertaking (LUT).
3. Select Financial Year: Choose the applicable financial year (e.g., 2025-2026). If you have previously submitted an LUT, upload the prior year’s acknowledgment copy.
4. Accept Statutory Undertakings: Select the checkboxes accepting the three statutory undertakings under Rule 96A (exporting goods within 3 months, realizing service proceeds within FEMA timelines, and paying tax with interest if defaulted).
5. Enter Independent Witnesses: Enter details of two independent adult witnesses (Name, Occupation, and Full Residential/Commercial Address).
6. Submit with DSC or EVC: Select the authorized signatory and sign using Class 3 Digital Signature Certificate (mandatory for Companies/LLPs) or Aadhaar EVC OTP (available for Proprietorships and Partnerships).
7. Download ARN Acknowledgment: Upon successful submission, the portal generates an Application Reference Number (ARN) instantly. Download and preserve this PDF acknowledgment for international client billing and audit records.

4. Essential Invoicing Rules & FIRC / BRC Documentation

When invoicing overseas clients under an LUT, exporters must ensure strict invoice compliance:

• Mandatory Invoice Endorsement: Every invoice must prominently feature the declaration: “SUPPLY MEANT FOR EXPORT OF SERVICES UNDER LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX”.
• Table 6A & Table 3.1(b) Reporting: Report export invoices in Table 6A of GSTR-1 with ‘Zero Tax’ and in Table 3.1(b) of GSTR-3B.
• Preserve FIRC / FIRA: Ensure your receiving bank or payment gateway (PayPal, Stripe, Wise, SWIFT) issues Foreign Inward Remittance Certificates (FIRC) or Foreign Inward Remittance Advices (FIRA) as statutory evidence of inward foreign convertible exchange under FEMA regulations.

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Disclaimer: This article provides general educational information regarding GST LUT filing under Section 16 of the IGST Act, 2017, and Rule 96A of the CGST Rules, 2017. Freelancers and export entities should consult qualified tax advisors regarding FEMA compliance and banking procedures.