Your Letter of Undertaking covers one financial year, so the LUT you are using now for FY 2026-27 stops covering invoices on 31 March 2027. To keep billing foreign clients without IGST from 1 April 2027, file a fresh LUT for FY 2027-28 in Form GST RFD-11 before you raise your first export invoice of the new year. It takes minutes on the GST portal, yet every April some exporters discover the gap only after an invoice has gone out.
Key takeaways
- An LUT is furnished for a financial year; FY 2027-28 runs from 1 April 2027 to 31 March 2028.
- File a new RFD-11 for FY 2027-28 on the GST portal, ideally in March 2027 or on the first working day of April.
- Check signatory, witnesses and registration details before filing; changes since last year are the usual cause of trouble.
- Without a valid LUT, export invoices would need IGST paid and a refund claimed later. Ask your CA how to treat any invoice raised in a gap.
- The LUT is a GST matter only; your monthly EDF under FEMA continues regardless.
Why renewal is a yearly event
Exports of services are zero-rated under Section 16 of the IGST Act. You can make them under LUT, without paying IGST, or by paying IGST and claiming a refund. The LUT is your undertaking that you will meet the export conditions, including receiving payment in convertible foreign exchange or in rupees where RBI permits. Because it is given for a financial year, it has to be given again for the next one.
If you are new to LUTs, start with our step-by-step article on filing Form GST RFD-11. This piece focuses on renewing it on time.
The renewal calendar
| When | What to do |
|---|---|
| Early March 2027 | Diary a renewal date; confirm who holds the GST portal login and signing credentials |
| Mid March 2027 | Check signatory, business details and witness information are current |
| Late March 2027 | File RFD-11 for FY 2027-28 if the portal allows filing for the coming year; save the acknowledgement |
| 1 April 2027 | If not yet filed, file before raising any export invoice |
| First export invoice of April | Confirm the LUT acknowledgement is on file and the invoice carries the LUT line |
| Through the year | Keep the acknowledgement with your GST records and share the reference with whoever prepares invoices |
When the portal begins accepting LUTs for the next year can vary, so check the portal or ask your CA in March. What does not vary is the principle: no export invoice dated 1 April 2027 or later should go out under LUT until the FY 2027-28 LUT is in place.
A pre-filing checklist
Most renewal problems come from things that changed during the year.
- Authorised signatory. Is the person signing on the GST portal still authorised? If a director, partner or proprietor's authorised person has changed, update the registration first.
- Digital signature or EVC. Check your DSC has not expired, or that EVC is available for your registration type.
- Witnesses. RFD-11 asks for two independent witnesses with names, addresses and occupations. Have them ready.
- Registration status. If your GSTIN was suspended, amended or is being cancelled, sort that out before filing.
- Business changes. A conversion from partnership to LLP or company, a merger or a new GSTIN means a new registration and a new LUT for that registration.
- Compliance history. The form includes declarations about compliance. If anything is unclear, discuss it with your CA before signing.
A worked example: the April gap
Coralstone Media LLP, a Mumbai video production firm, files its LUT every year. In FY 2026-27, the partner who usually signed retired in December and the GST registration was updated with a new designated partner. Nobody connected that change with the LUT.
On 2 April 2027, Coralstone raised a USD 18,500 invoice to a client in Los Angeles, with the familiar line "Supply meant for export under LUT without payment of IGST". On 9 April, its CA noticed that no LUT for FY 2027-28 had been filed, because the new partner did not have portal access set up.
The CA filed the LUT that week and then advised the firm on how to treat the 2 April invoice, which had been raised before the new LUT existed. The outcome was manageable but took time and attention during the busiest month of the year. A 15-minute check in March would have avoided it.
If you are in Coralstone's position, do not reissue or alter invoices on your own. Ask your CA how to handle any invoice raised before the LUT was filed.
What changes on your invoices
Nothing visible changes, which is why the lapse is easy to miss. Under a valid LUT, every export invoice should carry:
Supply meant for export under LUT without payment of IGST
Many exporters also add the LUT acknowledgement reference near that line, which makes it obvious whose job it is to update the reference each April. Our free GST invoice generator has a field for it, and the export invoice tool adds the LUT wording automatically.
The LUT and the EDF: two different calendars
It helps to separate your annual GST calendar from your monthly FEMA one.
| LUT (GST) | EDF (FEMA) | |
|---|---|---|
| Purpose | Export without paying IGST | Declare service exports to the AD bank |
| Frequency | Once per financial year | Once per month with export invoices |
| Filed with | GST portal | AD bank, STPI or SEZ Development Commissioner |
| Deadline | Before the first export invoice of the year | 30 days from the end of the invoice month |
| April 2027 example | File RFD-11 for FY 2027-28 | March 2027 invoices due on the EDF by 30 April 2027 |
The EDF does not change your GST obligations, and the LUT does not satisfy FEMA. In April, you will often be doing both: renewing the LUT and filing the March EDF, which is due 30 April 2027. Our EDF due date table lists every month.
This is general information, not legal or tax advice.
Frequently asked questions
Do I need to renew my LUT every year?
Yes. An LUT is furnished for a financial year, so you file a fresh Form GST RFD-11 for each new year, such as FY 2027-28 starting 1 April 2027.
When should I file the LUT for FY 2027-28?
Before your first export invoice dated on or after 1 April 2027. Many exporters file in late March if the portal allows it, or on the first working day of April.
What if I raised an export invoice before renewing the LUT?
File the LUT immediately and ask your CA how to treat the invoice raised in the gap. Do not alter or reissue invoices without advice.
Does renewing the LUT affect my EDF filing?
No. The LUT is a GST undertaking; the EDF is a monthly FEMA declaration to your bank. Both continue independently.
Bottom line
Put LUT renewal in your March diary every year, check your signatory and credentials, and file before the first April invoice. It is the cheapest compliance task you will do all year. Then keep invoicing with the right wording using 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.