A GST-registered freelancer invoices a US client for $2,000, then finds out three months later that their LUT lapsed on March 31 and every invoice since has technically needed IGST paid upfront, with a refund claim to follow. Nobody told them the filing was annual, not one-time, and now they are untangling a refund process instead of just re-filing a form that takes ten minutes.
This is a walkthrough of actually filing Form RFD-11 (the Letter of Undertaking) on the GST portal: the exact steps, what documents you need, when it must be renewed, and what happens if you miss the deadline. If you have not yet registered for GST or want the basics on why export of services is zero-rated, see the GST registration guide for freelancers and the guide to invoicing international clients first; this post picks up from there.
Who actually needs to file an LUT
Only GST-registered freelancers exporting services (invoicing clients located outside India) need to file an LUT. If you are below the ₹20 lakh GST registration threshold and not registered, this does not apply to you; export of services is zero-rated regardless, and you invoice at 0% without any LUT filing. If you are registered and export services without an active LUT on file, you are technically required to pay IGST on those invoices upfront and then file a separate refund claim, which is slower and more paperwork than filing the LUT once a year. This assumes the transaction actually qualifies as an export in the first place, which is not automatic just because the client is based abroad; see the guide on when a foreign client's project is not a GST export for the exceptions worth knowing before you file.
Step-by-step: filing Form RFD-11 on the GST portal
Log in to the GST portal with your GSTIN credentials, then navigate to Services, then User Services, then Furnish Letter of Undertaking (LUT). Select the financial year you are filing for from the dropdown; if you already have an LUT from the previous year, the system auto-fills that as your reference.
Fill in the self-declaration section, which confirms you will export goods or services without payment of integrated tax and will comply with GST law provisions. Enter the details of two independent witnesses (name, occupation, address), a mandatory field on the form. Preview the auto-generated LUT document, then sign it using either a Digital Signature Certificate (DSC, mandatory for companies and LLPs) or an Electronic Verification Code (EVC, an Aadhaar OTP-based option available to individual proprietors and partners, per the GST portal's LUT filing guidance) and submit.
Once submitted, an Application Reference Number (ARN) is generated instantly and the LUT is auto-acknowledged without any manual departmental review or physical documents to submit, unlike the older bond-based process this replaced. Download the acknowledgement PDF from the same portal section and keep it, since some clients or banks handling foreign remittances may ask for proof of your active LUT.
Renewal: the part everyone forgets
An LUT is valid for exactly one financial year (April 1 to March 31) and does not carry over automatically, under Rule 96A of the CGST Rules. File your renewal before April 1 each year to avoid any gap in coverage; the portal typically opens the window to file for the new year in the last two to three weeks of March. Set a recurring reminder for mid-March specifically, since this is the single most common way freelancers lose LUT coverage without realising it until an invoice is already out the door.
If your LUT lapses and you invoice a foreign client without one, the invoice does not become invalid, but the correct GST treatment becomes paying IGST upfront on that invoice and filing a separate refund claim (Form RFD-01) to recover it, a considerably slower path than the zero-rated invoicing you get with an active LUT. File the new year's LUT immediately if you catch a lapse, and going forward, invoice under the new one; do not wait to "clean it up later," since the paperwork only grows the longer invoices go out without coverage. See the guide on claiming a GST refund on export services for the exact filing process if IGST has already been paid.
Common mistakes that cause LUT filings to get rejected or delayed
Missing or mismatched witness details are the most frequent cause of a stuck submission; both witnesses need consistent, complete name, occupation, and address fields, and using the same two people you have used in prior years (if they are still reachable and willing) avoids re-verifying new details each time. Selecting the wrong financial year from the dropdown, especially in the first two weeks of a new year when old habits carry over, is the second most common error and simply requires re-filing under the correct year.
Attempting to sign with an expired or mismatched DSC causes silent submission failures; if you are a sole proprietor without a DSC, use the EVC/OTP option instead rather than troubleshooting certificate issues, since EVC is fully valid for individual freelancer filings and considerably simpler.
What this changes about your invoicing, practically
With an active LUT on file, every export invoice you raise to a client outside India is issued at 0% GST with no upfront tax payment or refund claim needed, which is the entire point of filing it. State on the invoice that it is an export of services under LUT (most invoicing tools, including Rinto, include this reference automatically once GST details are filled in), since this line is what a client's own compliance team or your bank may look for when processing the foreign remittance.
Rinto generates GST-ready invoices with your client's details auto-filled from your saved record, so once your LUT is active, your export invoices are formatted correctly without you re-checking the GST fields on every single one.
Frequently Asked Questions
How often do I need to file Form RFD-11 (LUT) for GST?
Once every financial year. An LUT filed for one year (April 1 to March 31) does not automatically extend to the next; you must file a fresh LUT before April 1 to keep your export invoices at 0% GST without interruption. Missing the renewal means your invoices technically require IGST paid upfront until a new LUT is filed.
Do I need a Digital Signature Certificate to file an LUT?
Not if you are an individual freelancer or sole proprietor. A DSC is mandatory for companies and LLPs, but individuals can sign and submit Form RFD-11 using an Electronic Verification Code (EVC), an OTP sent to your registered mobile number, which is faster to set up and fully valid for this filing.
What happens if I export services without an active LUT?
The invoice remains valid, but you are required to pay IGST on it upfront and then file a separate refund claim (Form RFD-01) to recover that tax, rather than invoicing directly at 0%. This is legal but significantly slower and more paperwork than simply keeping your LUT renewed each financial year.
Do I need to submit any documents along with Form RFD-11?
No. Per the GST portal's own filing guide, no physical documents are required for most individual freelancer filings. The form itself, completed online with your business details and two witnesses, is the submission, and approval is typically automatic and instant once signed via DSC or EVC, unlike the older bond-based process which required physical paperwork and bank guarantees.
Who needs the two witnesses required on the LUT form?
Form RFD-11 requires the name, occupation, and address of two independent witnesses as part of the self-declaration; they do not need to be present or sign anything separately outside the form itself. Using the same two people (a family member and a colleague, for example) across years is common practice and avoids re-collecting new details each renewal.