If you are not registered under GST, you can still invoice a foreign client; you simply issue a plain invoice without a GSTIN, without any GST charge and without the LUT declaration. The invoice should still identify you and the client clearly, describe the service, state the currency and amount and give payment instructions, because your bank, your tax return and, if it applies to you, your EDF all rely on it. What you must not do is show GST details you do not have.
Key takeaways
- Without a GSTIN you cannot charge GST or issue a GST tax invoice; issue a simple invoice instead.
- Leave out GSTIN, GST rates, IGST lines and the LUT wording, since the LUT is filed against a GSTIN.
- Include your name, address, PAN (optional but useful), client details, invoice number and date, service, currency, amount and bank details.
- Whether you should be registered for GST depends on your turnover and circumstances. Ask your CA, not a template.
- The EDF, where it applies, has a GSTIN field: confirm with your bank how to complete it if you are unregistered.
Who invoices without GST registration
Plenty of service exporters are not registered:
- new freelancers and consultants whose turnover is below the level that requires registration;
- individuals doing occasional work for overseas clients;
- small proprietorships that have not yet crossed into mandatory registration;
- people who were registered earlier but cancelled their registration.
GST registration rules for exporters of services involve thresholds and conditions that your CA should apply to your facts. Our article on whether GST registration is mandatory for exporters of services explains the considerations. This piece assumes you have confirmed you are not registered and want a correct invoice.
What to include, and what to leave out
| Element | Include? | Notes |
|---|---|---|
| Your name or business name and address | Yes | As per your bank account |
| PAN | Recommended | Useful for your bank and tax records |
| GSTIN | No | Never show one you do not have |
| "Tax invoice" title | No | Use "Invoice" |
| Invoice number and date | Yes | Use a simple, unbroken series |
| Client's name, address and country | Yes | Needed for your records and any EDF |
| Description of services and period | Yes | Specific enough to match the contract |
| SAC code | Optional | Helpful for classification; not a GST requirement if unregistered |
| Currency and amount | Yes | Show the currency clearly (USD, EUR, GBP) |
| GST, IGST, CGST, SGST lines | No | You cannot charge GST without registration |
| LUT wording | No | LUT is filed on the GST portal against a GSTIN |
| Payment terms | Yes | Net 15, net 30, due on receipt |
| Bank details for international transfer | Yes | Account name, number, bank name, SWIFT code, any intermediary bank your bank specifies |
| Signature | Optional | Many clients accept unsigned PDFs |
Using "Tax invoice" or adding GST lines when you are not registered creates a document that misstates your tax position. Keep it plain.
A sample layout
INVOICE
From: Priya Shah, Studio Saffron Illustrations, 14 Lake View Road, Udaipur, Rajasthan, India. PAN: [your PAN] To: Little Owl Books Ltd, 22 Market Street, Bristol, United Kingdom
Invoice no.: SSI-2026-017 Date: 6 October 2026 Due: 5 November 2026
Description Qty Rate (GBP) Amount (GBP) Illustrations for picture book "Moonlit Meadow", 12 spreads 12 180 2,160 Cover artwork 1 340 340 Total 2,500 Payment by international bank transfer to: [account name], [account number], [bank name and branch], SWIFT [code]. Please quote invoice no. SSI-2026-017. All bank charges outside India to be borne by the remitter.
Notice what is absent: no GSTIN, no tax lines, no LUT line. Our free export invoice generator lets you switch off GST fields for exactly this situation. For writing totals in words, the amount in words tool handles foreign currencies too.
Does the EDF still apply to you?
The EDF is a FEMA declaration and has nothing to do with GST registration. Whether you file depends on who you are:
- Individuals: on 7 October 2026, RBI said individuals providing services abroad are not required to report, and that FAQs would follow. The Regulations' text has not changed yet, so check with your bank.
- Proprietorships, firms, LLPs and companies: assume the EDF applies, registered for GST or not.
If you do file, field 1.8 asks for a GSTIN. If you have none, ask your bank how it wants the field completed, typically marked as not applicable. Every other field works as usual, and each invoice is one row in Part 2B.
Example. Priya, from the sample above, runs Studio Saffron as a proprietorship with a current account. She is not registered for GST. In October 2026 she raised two invoices to UK and US publishers. She asked her bank whether it needed an EDF from her; it said yes, as she operates a proprietorship with a business account, and told her to mark the GSTIN field as not applicable. She filed one EDF with two rows by 30 November 2026.
Getting paid and keeping records
- Ask the client to quote your invoice number when paying.
- Request a FIRA or payment advice from your bank for each foreign credit, and check the purpose code reflects your service.
- Keep a simple register: invoice number, date, client, currency, amount, date received, amount received.
- Where an invoice is paid short because of bank charges abroad, note it against the invoice.
When you later register for GST
If your turnover grows and you register, switch to GST-compliant export invoices from the date your registration takes effect: show your GSTIN, file an LUT in Form GST RFD-11 if you want to export without IGST, and add "Supply meant for export under LUT without payment of IGST" to each invoice. Do not reissue old invoices with a GSTIN they never had. This is general information, not legal or tax advice.
Frequently asked questions
Can I invoice a foreign client if I am not registered under GST?
Yes. Issue a plain invoice with your details, the client's details, the service, currency, amount and payment instructions. Do not show a GSTIN or charge GST.
Should I write the LUT wording on my invoice without GST registration?
No. The LUT is filed on the GST portal against a GSTIN, so an unregistered person cannot furnish one. Leave the wording off until you are registered and have an LUT in place.
Is my foreign client invoice still valid without GST?
It is a valid commercial invoice for requesting payment and for your income records. It is not a GST tax invoice, which only a registered person can issue.
Do I need to file the EDF if I am not registered under GST?
GST registration does not decide this. Businesses such as proprietorships, firms, LLPs and companies should assume the EDF applies; individuals should note RBI's 7 October 2026 statement and check with their bank.
Bottom line
Without GST registration, keep your export invoice honest and simple: full identities, clear service, currency, amount and bank details, with no GST lines. Revisit registration with your CA as you grow. Create a GST-free invoice in minutes with our free export invoice generator.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.