When does a service export business need GST registration?

For an agency, consultancy, IT firm or SaaS company that bills clients abroad, GST registration is rarely optional for long. Exports count towards the registration threshold, and without registration you cannot file a Letter of Undertaking (LUT) or claim back the GST you pay on rent, software and subcontractors.²⁸

This guide covers businesses: proprietorships with staff, partnership firms, LLPs and companies. If you are an individual freelancer deciding whether to register at all, read GST registration for freelancers who export instead. The law is stated as of October 2026.¹

What is GST registration for a service export business?

GST registration for a service export business is the GSTIN a supplier must obtain in the State or Union territory from which it makes taxable supplies once its aggregate turnover in a financial year exceeds ₹20 lakh, under section 22(1) of the Central GST (CGST) Act.¹ Section 2(6) of the CGST Act defines aggregate turnover as the value of all taxable supplies, exempt supplies, exports of goods or services and inter-State supplies of persons with the same Permanent Account Number (PAN), computed on an all-India basis and excluding taxes.²

• Threshold: ₹20 lakh; ₹10 lakh for special category States, but the Explanation to section 22 excludes Jammu and Kashmir, Arunachal Pradesh, Assam, Himachal Pradesh, Meghalaya, Sikkim and Uttarakhand from that group, so the ₹20 lakh limit applies there.¹
• Goods-only threshold: the ₹40 lakh threshold that some States allow applies only to suppliers engaged exclusively in the supply of goods, so it does not help a service business.¹
• Exports count: export turnover is part of aggregate turnover.²

For example, a design studio with ₹6 lakh of Indian billing and ₹18 lakh of US billing in 2026-27 has aggregate turnover of ₹24 lakh, above the ₹20 lakh threshold, even though most of its income is zero-rated.²

Which service export businesses need GST registration?

Service export businesses need GST registration once aggregate turnover exceeds the threshold, or earlier if another clause of section 24 applies; below the threshold, Notification No. 10/2017-Integrated Tax exempts them from compulsory registration as inter-State suppliers.¹⁴⁶

Section 24(i) of the CGST Act requires anyone making inter-State taxable supplies to register regardless of turnover, and section 7(5)(a) of the IGST Act treats a supply where the supplier is in India and the place of supply is outside India as inter-State.⁴⁵ The notification exempts persons making inter-State supplies of taxable services whose aggregate turnover does not exceed ₹20 lakh in a financial year (₹10 lakh in special category States other than Jammu and Kashmir).⁶

Note: Notification 10/2017-Integrated Tax refers to special category States "other than the State of Jammu and Kashmir", without the further exclusions now in the Explanation to section 22. Read literally, its ₹10 lakh limit could apply to exporters in States such as Assam, Himachal Pradesh or Uttarakhand, even though the section 22 threshold there is ₹20 lakh. If you work from one of those States and your aggregate turnover is between ₹10 lakh and ₹20 lakh, check with a CA.¹⁶

An agency that imports services, for example paying a foreign software vendor, should check whether it has a reverse charge liability. See RCM on imported services and SaaS tools and GST composition scheme and exports.

Why do many exporters register for GST before registration is compulsory?

Many exporters register for GST before they have to because section 25(3) of the CGST Act allows voluntary registration, and registration unlocks the LUT and input tax credit.³

• LUT: rule 96A of the CGST Rules lets a registered person export without paying integrated tax by furnishing an LUT in FORM GST RFD-11.⁸ Unregistered businesses do not charge GST at all, so this matters most once you would otherwise have to register.
• Input tax: only a registered person can claim input tax credit and a refund of unutilised credit on zero-rated supplies. An IT firm paying GST on office rent, laptops and cloud hosting can get that tax back. See refund of ITC on zero-rated supplies.
• Indian clients: a business with both Indian and foreign clients often registers for its domestic work and then uses the same registration for exports.

The trade-off is compliance: returns every period, even nil ones, and the rules on invoices, credit notes and records.

How does a service export business register for GST?

A service export business registers for GST by applying on the GST portal in FORM GST REG-01, under rule 8 of the CGST Rules.¹⁵

1. Part A: declare your PAN and State; the portal validates the PAN and verifies the mobile number and email by one-time password, then issues a temporary reference number.¹⁵
2. Part B: complete the application and upload the documents for your constitution (proprietorship, partnership, LLP or company), as listed in FORM GST REG-01 on the portal.¹⁵
3. Authentication: rule 8(4A) lets the applicant opt for Aadhaar authentication; applicants flagged on data analysis and risk parameters may also need biometric authentication and document verification at a facilitation centre.¹⁵
4. Approval: under rule 9, the officer approves within seven working days, or up to thirty days after physical verification where Aadhaar authentication is not done or the application is flagged.⁹
5. LUT: file FORM GST RFD-11 before the first export invoice of the financial year.⁸ See how to file an LUT.

How does GST registration work for an exporter with offices in more than one State?

GST registration for an exporter with offices in more than one State is State-wise and PAN-based. Section 25(1) requires registration in every State or Union territory where you are liable, section 25(2) allows separate registrations for multiple places of business within a State, and section 25(6) requires a PAN.³ Section 25(4) treats each registration as a distinct person, and section 25(5) treats establishments in different States as establishments of distinct persons.³

For example, for an IT company with delivery centres in Pune and Hyderabad:

• Invoices: each GSTIN raises its own export invoices for the work delivered from that State.³
• LUT: each GSTIN needs its own LUT; the GST portal FAQs say that where a new GSTIN is assigned, you must file a fresh LUT for that GSTIN for the remaining part of the financial year.¹¹
• Refunds: refunds are claimed GSTIN by GSTIN.
• Inter-office services: services between your own Pune and Hyderabad registrations are supplies between distinct persons, with their own GST treatment.³

What thresholds, documents and deadlines apply to GST registration for exporters?

GST registration for exporters turns on the ₹20 lakh threshold, a thirty-day window to apply and an LUT each financial year.¹³⁸

Keep a note of the date you crossed the threshold, because the thirty days run from it.

What happens if a service export business does not register for GST?

If a service export business does not register for GST, it cannot export under an LUT or recover the GST it pays on costs, and once it is liable it must apply within thirty days.³⁸

• No LUT: rule 96A lets a registered person furnish an LUT; an unregistered business cannot.⁸
• No input tax credit: only a registered person can claim input tax credit and a refund of unutilised credit on zero-rated supplies.
• Missed deadline: section 25(1) gives thirty days from the date you become liable to apply.³
• Reverse charge exposure: section 24 requires registration regardless of turnover for persons required to pay tax under reverse charge.⁴

Registration decisions depend on your turnover mix, States of operation and reverse charge exposure, so confirm with a chartered accountant (CA).

What is the timeline for GST registration and the steps that follow?

The timeline for GST registration runs from thirty days to apply, through approval in three to thirty days, to the LUT before the first export invoice.³⁸⁹¹⁰

After registration, an exporting business should also:

1. Complete Aadhaar authentication: under rule 10B for the persons it specifies; it is a condition for filing refund applications.¹²
2. Report exports: in the export details of GSTR-1 every return period.¹⁴
3. Check e-invoicing: from 1 August 2023, registered persons with aggregate turnover above ₹5 crore must issue e-invoices, and this covers export invoices.¹³ See e-invoicing for export of services.
4. Plan refunds: decide whether to export under LUT and claim ITC refunds, or pay IGST and claim that back. See GST refund on export of services and LUT renewal and validity.

What are the common mistakes with GST registration for service exporters?

The common mistakes with GST registration for service exporters come from leaving exports out of the turnover count.¹²¹¹

• Ignoring export turnover: exports count towards aggregate turnover.²
• Using the goods threshold: the ₹40 lakh threshold applies only to goods suppliers.¹
• One LUT for several GSTINs: each new GSTIN needs its own LUT.¹¹
• Opting for composition: exporters cannot use the composition scheme.⁵⁷
• Missing reverse charge: paying a foreign vendor can create a section 24 liability.⁴

A chartered accountant (CA) can confirm the timing and the number of registrations you need.