Can I file an LUT without GST registration?
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Short answer
No. Rule 96A of the CGST Rules gives the Letter of Undertaking option to "any registered person" who wants to export without paying integrated tax, and the GST portal files FORM GST RFD-11 from a registered taxpayer's login.12 An unregistered freelancer does not charge GST on any invoice, so there is nothing for an LUT to cover. You need one only after you register, voluntarily or because aggregate turnover crossed ₹20 lakh.34
Online tutors, illustrators and writers who are just starting with clients abroad often read that "exporters must file an LUT" and try to do so before they have a GSTIN. The portal will not let them, and the law does not ask them to.
Who can file an LUT?
Only a registered person can file an LUT. Rule 96A(1) of the CGST Rules says "any registered person availing the option to supply goods or services for export without payment of integrated tax" shall furnish a bond or LUT in FORM GST RFD-11 before exporting.1 The GST portal FAQs describe the same eligibility and exclude only persons prosecuted for tax evasion of ₹2.5 crore or more.2
Why does an unregistered exporter not need one?
The LUT is a promise to pay integrated tax if the export conditions are later not met, made by someone who would otherwise charge that tax.1 An unregistered supplier does not charge GST on any invoice, Indian or foreign, so the undertaking has nothing to attach to.
Staying unregistered is lawful while your aggregate turnover is within the threshold. Section 22(1) of the CGST Act sets ₹20 lakh (₹10 lakh in special category States), and Notification No. 10/2017-Integrated Tax exempts inter-State service suppliers, which includes exporters, up to the same limit.34 The freelancer registration guide explains how to count turnover, including foreign billing.
What should the invoice say if I am not registered?
An unregistered exporter's invoice shows your name and address, the client's name and address, the client's country, a description of the service, the amount and currency, and your bank details. Do not show GST, a GSTIN or an LUT reference. Many freelancers add a line such as "Supplier not registered under GST". The export invoice format guide lists the fields that apply once you are registered.
What changes when I register?
From your registration date, the LUT becomes relevant. File FORM GST RFD-11 for the financial year before the first export invoice you want to issue without IGST.1 The steps are in how to file an LUT on the GST portal, and an LUT can be filed mid-year; see filing an LUT in the middle of the year. If you are unsure whether you should already be registered, ask a chartered accountant (CA).
How did we verify this?
We checked this page against the sources below on 28 October 2026. Read our methodology or report an error.
- [1]CBIC: CGST Rules, 2017, rule 96A (export under bond or Letter of Undertaking)
- [2]GST Portal FAQs: Filing of Letter of Undertaking (FORM GST RFD-11) (checked 28 October 2026)
- [3]CBIC: CGST Act, 2017, section 22 (persons liable for registration)
- [4]Notification No. 10/2017-Integrated Tax (exemption from registration for inter-State suppliers of taxable services), GSTZen reproduction
Frequently asked questions
My foreign client asked for my LUT number. I am not registered. What do I send?+
Explain that you are not registered under GST, so no GST applies and no LUT exists. Your invoice can state that you are not registered under GST.
Does an unregistered exporter need a GSTIN on the invoice?+
No. A GSTIN exists only after registration, which is not required while aggregate turnover stays within ₹20 lakh for a service exporter.34
Once I register, when must I file the LUT?+
Before your first export invoice without IGST. Rule 96A requires the LUT to be furnished prior to export.1
Who is excluded from filing an LUT even after registering?+
The GST portal FAQs exclude persons prosecuted for tax evasion of ₹2.5 crore or more; they furnish a bond instead.2
This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.
Keep reading
How do you file an LUT for export of services on the GST portal?
Step-by-step guide to filing a Letter of Undertaking in FORM GST RFD-11 for export of services: eligibility, validity, late filing and the ARN on invoices.
GSTDo freelancers with foreign clients need GST registration?
An individual freelancer billing foreign clients must register for GST only above ₹20 lakh aggregate turnover. How to count it, and when registering early makes sense.
InvoicingWhat should an export of services invoice contain under GST?
The fields an export of services invoice needs under Rule 46 of the CGST Rules, the LUT endorsement wording, currency, numbering and a sample layout.
GSTHow does GST apply to export of services from India?
How GST works when you bill a foreign client from India: the five export conditions, LUT vs IGST refund, records to keep, payment deadlines and mistakes.