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 may have needed IGST paid upfront, with a refund claim to follow unless the officer condones the delay. 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. An LUT is only for GST-registered persons; if you are not registered you do not charge GST and have nothing to file. If you are registered and export services without an active LUT on file, you may have to pay IGST on those invoices upfront and then claim a refund, 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.
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, address, occupation), which the online form requires. Preview the auto-generated LUT document, then sign it using either a Digital Signature Certificate (DSC) or an Electronic Verification Code (EVC, an OTP sent to the authorised signatory's registered mobile and email), as the GST portal's LUT guide describes, and submit.
Once submitted, an Application Reference Number (ARN) and an acknowledgement are generated, with no physical documents to submit, unlike the older bond-based process this replaced. The officer may approve it, ask for clarification or reject it, and if no action is taken within 3 working days it shows as Deemed Approved. 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
Rule 96A of the CGST Rules requires the LUT before you export, and CBIC Circular 8/8/2017 says it is valid for the whole financial year in which it is tendered. So it expires on March 31 and does not carry over automatically. File the new year's LUT before your first export in April, and check the financial year dropdown in March to see whether the next year is already offered. Set a recurring reminder, since a lapsed LUT is easy to miss 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 you may have to pay IGST upfront on that invoice and claim a refund (Form RFD-01) to recover it, a slower path than the zero-rated invoicing you get with an active LUT. CBIC Circular 37/2018 lets officers condone a late LUT and allow the export under LUT after the fact, case by case, so ask your jurisdictional officer before you pay. 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
Both witnesses need complete name, address and occupation fields, and you can reuse the same two people from earlier years if they are still willing. Select the correct financial year from the dropdown, especially in the first weeks of a new year when old habits carry over; a wrong year means re-filing under the correct one.
If your DSC has expired or does not match the registered signatory, the signing step can fail; if you are a sole proprietor without a DSC, use the EVC (OTP) option instead, which the portal offers for authorised signatories.
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. If you sell through Upwork or Fiverr, the guide on GST on platform fees covers what those platforms say about tax on their own fees.
For the rupee value on an export invoice, see the guide on the exchange rate on a GST export invoice.
Frequently Asked Questions
How often do I need to file Form RFD-11 (LUT) for GST?
Once every financial year. An LUT is valid for the whole financial year in which it is tendered (April 1 to March 31) and does not extend to the next, so file a fresh LUT before your first export of the new year to keep your export invoices at 0% GST. Without one, you may have to pay IGST upfront until a new LUT is filed, unless the officer condones the delay.
Do I need a Digital Signature Certificate to file an LUT?
Not necessarily. The portal accepts either a DSC or an Electronic Verification Code (EVC), an OTP sent to the authorised signatory's registered mobile and email, so a sole proprietor can sign with EVC. Companies and LLPs usually use a DSC.
What happens if I export services without an active LUT?
The invoice remains valid, but you may have to pay IGST on it upfront and then claim a refund (Form RFD-01), rather than invoicing directly at 0%. Circular 37/2018 lets officers condone a late LUT case by case. Either way, keeping your LUT renewed each financial year is simpler.
Do I need to submit any documents along with Form RFD-11?
No. Per the GST portal's own filing guide, no documents need to be uploaded for a fresh LUT; uploading is optional only for a previously approved manual LUT. The form itself, completed online with your business details and two witnesses, is the submission. After you sign it with DSC or EVC, the status can show Submitted, Approved, Deemed Approved after 3 working days, or Rejected, unlike the older bond-based process.
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; you enter their details on the online form. You can reuse the same two people across years if they are still willing, which saves collecting new details each renewal.