LUT under GST for freelancers: what it is, how to renew

From the Export Desk, the LUT filing cardLook inside the Export Desk

What is an LUT, and why do freelancers file one?

A registered person can export services in one of two ways. One is to pay IGST on each export invoice and claim it back later as a refund (source 1). The other is to furnish an LUT and export without paying IGST at all (source 2). With an LUT, no tax leaves your account to wait in a refund queue, and the invoice stays simple.

The LUT is a self-declaration. Circular No. 8/8/2017-GST, of 4 October 2017, says a declaration that you have not been prosecuted is accepted unless there is specific information otherwise, and that an LUT not accepted within three working days is deemed to be accepted (source 3).

Who can file an LUT?

A registered person who wants to supply goods or services for export without paying IGST, unless they have been prosecuted for tax evasion of ₹2.5 crore or more (source 2). It is filed from the business’s own GST login, and signed by one of its authorised signatories (source 4).

If you aren’t registered for GST, there is no LUT to file (source 2). Your invoices to clients abroad are plain invoices without the GST lines; the export invoice guide says more.

How do you file it on the GST portal?

Have your two witnesses’ details to hand before you start. The steps are the same every year (source 2, source 4):

Log in to the GST portal and go to Services > User Services > Furnish Letter of Undertaking (LUT).
Choose the financial year from the “LUT Applied for Financial Year” list. In March, that is the year about to begin (source 1).
Upload an earlier LUT only if you filed one on paper: one file, PDF or JPEG, up to 2 MB. If you have none, skip this step.
Tick the declarations, and read them first: you undertake to pay the tax due, with interest, if the conditions aren’t met (source 5).
Enter two independent and reliable witnesses: the name, address and occupation of each.
Enter the place of filing and choose the authorised signatory.
Preview the form, and check the financial year once more.
Sign with EVC or a DSC. EVC sends a one-time code to the signatory’s registered mobile number and email address.
Note the ARN, the application reference number the portal shows and sends to your registered mobile number and email address, and download the acknowledgement.

Then copy the ARN, its date and the financial year into your invoice template, so every export invoice that year carries them.

How long does an LUT last?

One financial year. You file it for the financial year you choose, and the portal marks it “Expired” at the end of that year (source 2, source 4). So an LUT for 2026-27 covers the exports you make after filing it, up to 31 March 2027, and none after that date.

You don’t wait for a letter. If no action is taken on your LUT within three working days, the portal shows it as “Deemed Approved” (source 2).

When should you renew it for 2027-28?

Before your first export invoice dated on or after 1 April 2027. The LUT must be in place before the export it covers (source 2), and this year’s doesn’t carry over to the next (source 1). The portal lets you choose the coming financial year, so you can file the 2027-28 LUT in March 2027, before the year starts (source 1).

Early March 2027: file the LUT for 2027-28, choosing 2027-28 as the financial year.
The same day: save the acknowledgement, and put the new ARN and its date in your invoice template, ready for April.
From 1 April 2027: every export invoice carries the new ARN and its date.
March 2028: do the same for 2028-29.

Where does the LUT appear on your invoice?

Every export invoice under an LUT carries this endorsement, in these words, under the proviso to rule 46 of the CGST Rules (source 6):

SUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX

Put your LUT’s ARN and the date it was filed under the endorsement. The rule’s text doesn’t ask for them; it is the usual practice, and it shows which LUT the invoice relies on (source 6). The export invoice guide sets out all ten lines an export invoice under LUT needs, and the free export invoice check tests an invoice against them, including whether your LUT’s financial year matches the invoice date.

What if you invoiced before filing?

It is easy to do in April, when last year’s LUT has expired and this year’s isn’t filed yet. There are two ways back, and your CA should choose between them for your case:

Pay the IGST on those invoices, and claim it back later as a refund (source 1).
Ask for the delay to be condoned. The CBIC’s Circular No. 37/11/2018-GST of 15 March 2018 says the delay in furnishing an LUT “may be condoned”, and export under the LUT allowed after the event, case by case (source 7). On 2 December 2025 the Karnataka High Court relied on that circular in Prime Perfumery Works, setting aside a refund refused only because the LUT was filed after the export (source 8).

What does the LUT ask of you in return?

That the money arrives. Under rule 96A of the CGST Rules, as amended in July 2024, if the money for an exported service hasn’t been received within one year of the invoice date, or within the FEMA period if that is later, you pay the IGST with interest within 15 days after that period ends (source 5). Under the RBI’s regulations in force from 1 October 2026, the FEMA period for services is nine months from the invoice date (source 9). So unless your bank extends that period, the GST date falls about one year and 15 days after the invoice.

The guide to exporting services from 1 October 2026 sets out both clocks side by side.

From the kit. The Export Desk carries these steps on an LUT filing card, to keep beside you while you file, with what to do afterwards and the mistakes to avoid on its second page. This is its first page.

Questions to ask your CA

I invoiced a client abroad before filing this year’s LUT. Should I pay the IGST and claim a refund, or ask for the delay to be condoned?
Who can be my two witnesses? May one of them be a relative?
For my business, who should sign the LUT, and with EVC or a DSC?
If a client hasn’t paid within the year, what do I pay, and what happens to my LUT?
How should my LUT’s ARN and its date appear on my invoices?
Do I need a fresh LUT if my business’s name or registration changes during the year?

Sources

SetIndiaBiz. GST LUT Filing FY 2026-27: Easy Guide to Export Without IGST, 5 March 2026. Secondary source. Read on 12 October 2026.
Goods and Services Tax Network. Furnishing of Letter of Undertaking for Export of Goods or Services, the GST portal’s user guide. Primary source. Read on 12 October 2026.
Central Board of Excise and Customs (now the CBIC). Circular No. 8/8/2017-GST, 4 October 2017: Clarification on issues related to furnishing of Bond/Letter of Undertaking for exports, a copy on the GST Council’s website. Paragraphs 2(d) and 2(e). Primary source. Read on 12 October 2026.
GSTZen. User Manual: Filing of Letter of Undertaking (FORM GST RFD-11). Secondary source. Read on 12 October 2026.
Central Board of Indirect Taxes and Customs. Rule 96A, Export of goods or services under bond or Letter of Undertaking, CGST Rules, 2017, the CBIC’s own text, with sub-rule (1)(b) as substituted by Notification No. 12/2024-Central Tax of 10 July 2024: the tax due, with interest, 15 days after one year from the invoice date, or after the FEMA period with any extension if that is later. Primary source. Read on 13 October 2026.
Central Board of Indirect Taxes and Customs. Rule 46, Tax invoice, CGST Rules, 2017, the CBIC’s own text in its tax information repository, with its amendments up to Notification No. 20/2024-Central Tax of 8 October 2024, including the export proviso and its endorsement. Primary source. Read on 13 October 2026.
TaxGuru. Clarifications on exports related refund issues in Circular No. 37/11/2018-GST, reproducing paragraph 4.1 of the circular. Secondary source. Read on 12 October 2026.
Masters India. Can GST Refund Be Rejected if LUT Is Filed After Export?, on Prime Perfumery Works v. Assistant Commissioner of Central Tax, Karnataka High Court, 2 December 2025. Secondary source. Read on 12 October 2026.
Reserve Bank of India. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, as amended up to 22 September 2026. Regulation 5(1). Primary source. Read on 12 October 2026.

What changed in this guide

13 October 2026. Rules 46 and 96A are now cited from the CBIC’s own text of the CGST Rules, in place of three secondary sources. Nothing in the steps or the dates changed.
12 October 2026. Written, and checked against the sources above, including the portal’s steps for Form GST RFD-11.