A GST-registered freelancer exports services to a US client, forgets to renew their LUT before April 1, and keeps invoicing at 0% anyway out of habit. Three months later a compliance review flags it: every one of those invoices technically owed IGST upfront, and now there is unpaid tax sitting on the books instead of a filing that takes ten minutes a year.
Paying the IGST is not the end of the story. That tax is recoverable through a GST refund claim on Form RFD-01, and here is exactly how to file it, what documents you need, how long it takes, and the deadlines that determine whether you get the money back at all.
When you actually need to claim a GST refund on exports
This applies specifically to a GST-registered freelancer who exported services (invoiced a client located outside India) without an active LUT on file, meaning IGST was charged and paid on those invoices instead of the usual 0% zero-rated treatment. If you filed and kept your LUT current, you never pay this tax in the first place and this entire process does not apply to you. See the guide to filing Form RFD-11 (LUT) for export services if you have not set that up, since it is the far simpler path and avoids the refund process entirely.
The refund is claimed under the category "Refund of IGST paid on export of services with payment of tax," filed as Form RFD-01 electronically on the GST portal, per the portal's official refund filing process. This is the same mechanism used whether the IGST was paid because your LUT lapsed or because you simply chose to invoice with tax paid instead of under LUT, which some exporters do deliberately for other reasons.
The two-year deadline you cannot miss
You have exactly two years from the "relevant date" to file this refund claim, under Section 54(1) of the CGST Act. For export of services where payment is received after the service is supplied, which is the normal case, the relevant date is the date you actually received payment in convertible foreign exchange, not the invoice date and not the date the work was delivered. If you have not yet registered for GST, the GST registration guide for freelancers covers the ₹20 lakh threshold and when this whole process starts applying to you.
This matters because a freelancer who delivered work in January but got paid in June has their two-year clock starting in June, not January. Track the payment receipt date for every export invoice you paid IGST on, since that is the date that determines whether your claim is even still eligible to file.
What documents you need before you file
Statement 2, which lists your export invoices with the corresponding FIRC or BRC numbers proving you actually received the foreign exchange payment, is mandatory for this refund category and is uploaded through the GST portal's offline utility, per CBIC Circular 125/44/2019-GST. Along with that, you need the actual tax invoices for the exports being claimed and, depending on the claim, a self-certified or CA-certified statement per the same circular's certification rules.
Get your FIRC (Foreign Inward Remittance Certificate) from your bank as soon as an international payment lands, rather than requesting it months later when you sit down to file the refund. Banks can take time to issue these on request, and an FIRC older than roughly 9 months is a common source of rejection or delay when it does not clearly tie back to the invoice being claimed. A FIRC is not the same as the FIRA your bank sends automatically, see the guide on FIRC vs FIRA, the difference that can cost you a refund for exactly why the two get confused and which one this filing actually requires.
Provisional refund: what changed in October 2025
Under Section 54(6) of the CGST Act and Rule 91, exporters have historically been eligible for a provisional refund of 90% of the claimed amount within 7 days of the acknowledgement (RFD-02) being issued, with the balance following full scrutiny. As of Notification No. 13/2025-Central Tax (effective October 1, 2025), this 90% provisional sanction is no longer automatic for every eligible claim. It is now tied to the GST system's own risk-based evaluation of the application, so treat the fast 90% payout as something that may happen rather than something guaranteed, and budget your cash flow around the full 60-day disposal window instead of assuming the quick partial refund.
Why claims get rejected and what to fix before you file
A mismatch between the FIRC or BRC amount and the invoice value is the most common reason a claim gets flagged, since the officer is directly comparing what you say you exported against what the bank confirms actually arrived, and currency conversion timing differences can throw this off if you are not careful about which figures you report.
Invoice details that do not match your GSTR-1 filings for the same period are the second common issue, since the refund application is cross-checked against your existing returns rather than treated as an independent submission. And if you have both zero-rated exports and domestic supplies in the same period, incomplete or missing proportionate ITC reversal calculations can also hold up the claim. If a deficiency memo (Form RFD-03) is issued against your application, the only path forward is a fresh application addressing the gap, not a resubmission of the same one, so it is worth getting the documentation right the first time rather than filing quickly and fixing it later.
Rinto's GST-ready invoicing keeps your export invoice details consistent and organised by client, so when it comes time to reconcile invoice values against FIRC amounts and your GSTR-1 filings for a refund claim, you are working from one accurate record instead of piecing invoice history together after the fact.
Frequently Asked Questions
How long do I have to claim a GST refund on export services?
Two years from the relevant date, under Section 54(1) of the CGST Act. For export of services where payment is received after the work is delivered, which is the normal case, the relevant date is the date you actually received the payment in convertible foreign exchange, not the invoice date or delivery date. Track payment receipt dates carefully, since this is what determines whether a claim is still eligible.
What is the minimum amount for a GST refund claim?
₹1,000 per tax head, under Section 54(14) of the CGST Act. Amounts below this threshold cannot be claimed as a refund. This rarely affects freelancers with genuine export income, since even a single mid-sized international invoice's IGST amount typically exceeds this threshold easily.
Do I get my refund quickly, or does it take months?
A provisional refund of 90% of the claim can be issued within 7 days of acknowledgement, but since October 2025 this fast-track is based on the GST system's own risk evaluation of your application rather than automatic for every claim. The full disposal, including the remaining balance, is required within 60 days of filing under Section 54(6), with 6% annual interest owed to you if the department takes longer than that.
What documents do I need to file Form RFD-01 for export services?
Statement 2, listing your export invoices alongside the corresponding FIRC or BRC numbers as proof of receiving the foreign exchange payment, is mandatory. You also need the actual tax invoices being claimed and, in some cases, a self-certified or CA-certified statement. Get your FIRC from your bank soon after each international payment lands rather than requesting it months later, since delays and mismatches here are the most common cause of a stuck claim.
What happens if my refund claim gets rejected?
A deficiency memo (Form RFD-03) is issued under Rule 90(3) of the CGST Rules, and once it is issued, you cannot simply resubmit the same application. You need to file a fresh RFD-01 addressing whatever gap caused the deficiency, most commonly a mismatch between your FIRC/BRC and invoice values, or invoice details that do not line up with your GSTR-1 filings for the same period. Getting your documentation consistent before you file the first time avoids this delay entirely.