Introduction
Exporting goods or services from India involves more than finding overseas customers and issuing invoices. Exporters must maintain accurate documentation, report transactions correctly under GST and monitor payments due from foreign customers. Missing documents, unreconciled invoices or delayed export proceeds can create complications for tax compliance, banking procedures and financial reporting.
A Letter of Undertaking, commonly called an LUT, allows eligible GST-registered exporters to make qualifying exports without paying Integrated Goods and Services Tax (IGST) upfront, subject to applicable conditions. However, filing an LUT does not remove the need to maintain export evidence, report transactions accurately or comply with the applicable foreign-exchange requirements.
A well-organised export documentation system helps businesses connect each export invoice with its shipping or service records, GST reporting, bank receipts and outstanding payment status.
This guide explains LUT filing, export documentation, pending realisation tracking and practical controls that businesses can implement to improve their export compliance process.
What Is an LUT for Exporters?
A Letter of Undertaking is a declaration furnished by an eligible registered person under the GST framework to export qualifying goods or services without payment of IGST, subject to the prescribed conditions.
The undertaking is furnished in Form GST RFD-11 through the GST Portal. The portal's official guidance explains that taxpayers can access the LUT facility through Services, User Services and Furnish Letter of Undertaking, select the relevant financial year, complete the declaration and file it using the available authorised signing method.
Exports are generally treated as zero-rated supplies under GST. Eligible exporters can use the LUT route instead of paying IGST on qualifying exports and may claim a refund of eligible accumulated input tax credit, subject to the applicable rules and conditions. The alternative route of paying IGST and claiming a refund is also subject to the applicable legal framework.
An LUT should not be treated as a substitute for export invoices, shipping evidence, service-delivery records or proof of payment. These records serve different purposes and should be maintained separately.
Who Should Consider Filing an LUT?
An exporter registered under GST who intends to make eligible exports without payment of IGST should assess whether the LUT route applies to their transactions.
This may include businesses exporting physical goods, software, consulting services, design services or other qualifying services to overseas customers.
Before filing, businesses should confirm that the transaction qualifies as an export under the applicable GST provisions. For services, this includes checking the relevant conditions governing the supplier, recipient, place of supply, payment and other requirements. Not every transaction involving a foreign customer automatically qualifies as an export of services.
Businesses should also review any specific restrictions or exceptions applicable to their activities.
How to File an LUT on the GST Portal
The following is a practical overview of the filing process. Follow the current portal instructions for the relevant financial year.
Step 1: Log in to the GST Portal
Access the official GST Portal using the business's authorised credentials. Confirm that the correct GSTIN is selected before starting the application.
Step 2: Open the LUT Facility
Navigate to Services → User Services → Furnish Letter of Undertaking (LUT).
Select the financial year for which the LUT is being furnished. The official GST Portal manual identifies this navigation and the financial-year selection as part of the filing process.
Step 3: Complete the Declaration
Review the undertaking and complete the fields required by the portal. The filing process may request details such as the place of filing, authorised signatory and witness information.
Where the portal requires a previous LUT document, upload it in the permitted format and size. Verify the current instructions rather than relying on an old saved application or a screenshot from an earlier filing.
Step 4: Review and Sign
Preview the application and check the financial year, GSTIN, declaration and signatory details.
The portal manual describes the options to sign and file using a registered Digital Signature Certificate (DSC) or Electronic Verification Code (EVC), where available to the taxpayer.
Step 5: Save the Acknowledgement
After successful filing, retain the generated Application Reference Number (ARN) and download the acknowledgement.
Save the filed LUT in the business's compliance folder and link it to the relevant financial year. Confirm that the record is accessible to the GST, finance and accounts teams.
Export Documentation Checklist for Businesses
Export documentation requirements differ according to the type of export, the goods or services involved, the payment arrangement and the relevant regulatory requirements. The following records form a useful starting point.
1. Customer Contract or Purchase Order
Maintain the customer agreement, purchase order or other commercial confirmation that establishes the transaction.
The document should clearly identify the customer, goods or services, pricing, currency, payment terms, delivery conditions and other relevant commercial details.
For recurring customers, retain the applicable master agreement and document any changes to pricing or payment conditions.
2. Export Invoice
The export invoice should contain the required supplier and customer information, invoice number and date, description of the goods or services, quantity where relevant, value, currency and other particulars required by the applicable rules.
For GST purposes, confirm that the invoice reflects the correct export treatment and includes the required declarations and details.
Use a consistent invoice numbering system so that every transaction can be traced from the accounting ledger to the GST return and payment records.
3. Shipping and Customs Documents for Goods
For physical exports, maintain the documents relevant to the shipment. Depending on the transaction, these may include the shipping bill, transport document, packing list, commercial invoice, export order and customs clearance evidence.
The exact documents required depend on the goods, transport method and applicable customs and trade requirements.
Where shipping details become available after the relevant GST reporting has been completed, review the prescribed amendment or reporting process. The GST Portal's GSTR-1 guidance explains how shipping bill information can be furnished later through the relevant amendment section when it was not available at the time of filing.
4. Service Delivery Evidence
Service exporters should maintain evidence demonstrating what was supplied and when it was delivered.
Depending on the nature of the work, this may include a signed statement of work, project milestones, deliverable acceptance, timesheets, consulting reports, software delivery records or email confirmations from the customer.
Service exporters should also maintain documentation supporting the applicable export-of-services conditions under GST.
5. GST Returns and LUT Acknowledgement
Keep the LUT acknowledgement with the relevant export invoice records. Reconcile export invoices with the appropriate GST return data, including the relevant GSTR-1 reporting and other applicable returns.
For businesses seeking refunds of accumulated input tax credit, maintain the additional information and supporting documents required for the relevant refund application.
The GST Portal provides a separate process for applying for refunds relating to exports made without payment of IGST, subject to the applicable conditions.
6. Bank and Foreign-Exchange Records
Maintain records showing the receipt of export proceeds, such as bank advice, inward-remittance information and the relevant bank-issued realisation evidence where applicable.
Depending on the transaction and banking process, exporters may also need supporting records linking a receipt to a particular export invoice.
If the customer makes a partial payment, pays multiple invoices together or deducts an agreed commercial adjustment, document how the receipt has been allocated.
What Is Pending Export Realisation?
Pending export realisation refers to the portion of an export invoice that remains unpaid or has not yet been reconciled with the exporter's records.
For example, an exporter issues an invoice for ₹8,00,000 to an overseas customer. The customer pays ₹5,00,000, leaving ₹3,00,000 outstanding.
The business should record the invoice as partially realised and continue tracking the remaining amount until it is received, otherwise validly settled or resolved through an appropriate documented process.
A pending balance is not automatically a compliance violation. It may reflect an agreed credit period, a customer dispute, a delayed bank transfer or another commercial circumstance. The key is to identify the reason, monitor the applicable deadline and take appropriate action.
How to Build an Export Realisation Register ?
An export realisation register is a central record connecting export invoices, customer payments and outstanding balances.
Businesses can maintain this register in a spreadsheet, accounting system or enterprise resource planning platform.
Recommended fields include:
| Field | What to record |
|---|---|
| Export invoice number | Unique invoice reference |
| Invoice date | Date of issue |
| Customer | Overseas buyer or recipient |
| Country | Customer's country |
| Export type | Goods or services |
| Invoice currency | Currency in which the customer is billed |
| Invoice value | Total invoice amount |
| GST reporting period | Period in which the export is reported |
| LUT financial year | Relevant LUT record, where applicable |
| Expected payment date | Due date under the contract |
| Amount received | Total receipts allocated to the invoice |
| Outstanding balance | Invoice value less allocated receipts, using a consistent currency basis |
| Last follow-up date | Date of the latest customer follow-up |
| Reason for delay | Commercial or operational explanation |
| Bank evidence | Reference to relevant receipt records |
| Compliance deadline | Applicable regulatory date, verified for the transaction |
| Next action | Follow-up, bank query, documentation or escalation |
The register should distinguish the commercial payment due date from a statutory or regulatory deadline. They may be different.
For invoices denominated in foreign currency, define a consistent method for recording the original currency value and its accounting value in Indian rupees. Exchange differences and bank charges should be recorded according to the applicable accounting treatment.
How to Track Pending Export Payments
Step 1: Set a Clear Payment Due Date
Record the payment terms agreed with the customer. For example, the contract may require payment within 30 days of the invoice date or after acceptance of the goods.
The due date should come from the actual commercial agreement, not from a default assumption.
Step 2: Reconcile Bank Receipts Regularly
Match bank credits with outstanding export invoices. Check the remitter's details, currency, amount and relevant payment references.
If a receipt covers multiple invoices, document the allocation. If the receipt is lower than expected, determine whether the difference relates to bank charges, a partial payment, an agreed deduction or an unresolved discrepancy.
Step 3: Follow Up Before the Due Date
Send a payment reminder before the expected payment date and maintain a record of customer responses.
If the customer disputes the invoice, record the issue, the responsible employee and the expected resolution date.
Step 4: Review Overdue Invoices
Prepare an ageing report that groups outstanding invoices into useful periods, such as not yet due, 1–30 days overdue, 31–60 days overdue and more than 60 days overdue.
These bands are internal management categories, not statutory deadlines. They help the finance team identify invoices requiring attention.
Step 5: Flag Regulatory Deadlines Separately
The accounts team should identify any applicable GST or foreign-exchange deadline associated with the transaction and record the source used to verify it.
Escalate approaching deadlines to the finance head or authorised compliance professional rather than waiting for the commercial payment to become significantly overdue.
Step 6: Document Extensions and Exceptions
Where an extension, approved adjustment or other permitted exception is relevant, maintain the appropriate correspondence, approvals and supporting records.
Do not assume that a customer agreement automatically changes a regulatory deadline. Confirm the applicable procedure with the authorised bank or relevant professional.
GST LUT Conditions and Pending Export Proceeds
Exporters using an LUT must monitor the conditions attached to that undertaking.
Under Rule 96A of the CGST Rules, the framework distinguishes between goods and services. The rule provides a specified period for exporting goods and a separate period for receiving payment for services supplied for export, with the possibility of an extension as permitted by the competent authority. The current rule text provides for export of goods within three months after the invoice date, or an extended period allowed by the Commissioner, and receipt of payment for export services within one year after the invoice date, or an extended period allowed by the Commissioner.
This distinction is important: the GST LUT condition for completing an export is not the same as the foreign-exchange timeline governing realisation and repatriation of export proceeds.
Where the relevant Rule 96A condition is not met, the exporter may need to pay the applicable tax and interest in accordance with the rule, unless a permitted extension or other applicable provision changes the position.
Businesses should review the rule applicable to their transaction and reporting period rather than applying one deadline to all exports.
Foreign-Exchange Requirements for Export Realisation
GST compliance is only one part of export compliance. Exporters must also consider the applicable foreign-exchange framework and the procedures followed by their authorised dealer bank.
Important for October 2026: The Reserve Bank of India issued the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, which came into force on 1 October 2026 and superseded the 2015 regulations, subject to the provisions concerning earlier acts and omissions.
Because the applicable requirements may depend on the type of export, the transaction date, any transitional provision and the relevant RBI directions, businesses should not rely on an old standard deadline without checking the current framework.
For pending invoices, the exporter should contact its authorised dealer bank to confirm the applicable realisation and repatriation deadline, required export records, reporting status and the procedure for any extension or other permitted treatment.
Keep the bank's guidance and any relevant approval or correspondence with the invoice file. This creates a clear record of the action taken on the outstanding amount.
Common Export Documentation and Realisation Mistakes
Treating the LUT as the Only Required Document
An LUT does not replace export invoices, customs records, service-delivery evidence, GST reporting or bank documentation. Maintain each record according to its purpose.
Not Linking Receipts to Invoices
A bank receipt may not clearly identify the invoice it settles. Without a documented allocation, the business may report an incorrect outstanding balance or struggle to explain the receipt later.
Confusing Commercial and Regulatory Deadlines
A customer may have 60 days to pay under a contract, while a separate regulatory requirement may apply to the export transaction. Maintain both dates and track them independently.
Ignoring Part-Payments and Bank Charges
Recording a receipt as full settlement without reviewing the amount received and any deduction can distort the accounts receivable balance.
Using an Outdated LUT Record
Maintain the LUT acknowledgement for the relevant financial year and verify the current filing status when preparing GST reports or refund applications.
Delaying Escalation of Overdue Invoices
If a payment is overdue, assign responsibility for follow-up and determine whether the issue is commercial, documentary or regulatory. Escalate unresolved cases early enough to evaluate the available options.
A Monthly Export Compliance Review
A monthly review helps keep export documentation and receivables aligned.
The finance team should compare the export invoice register with the accounting ledger, GST reporting, customs or service-delivery records and bank receipts. Differences should be assigned to a responsible person and tracked until resolved.
The review should identify invoices that are approaching their contractual due dates, invoices that are overdue, balances that are partially realised and transactions with approaching regulatory deadlines.
The team should also verify that the LUT acknowledgement and other relevant compliance documents are stored in an accessible location. Where refunds are being claimed, the business should check that the relevant returns and supporting records meet the current requirements.
Frequently Asked Questions
1. What is an LUT in GST for exporters?
An LUT is a Letter of Undertaking furnished by an eligible GST-registered person to export qualifying goods or services without payment of IGST upfront, subject to the applicable conditions. It is furnished in Form GST RFD-11 through the GST Portal.
2. Does an exporter need to file an LUT every financial year?
Exporters should verify their LUT status for each relevant financial year and furnish the undertaking for the year in which they intend to use the facility, following the current GST Portal procedure. Retain the acknowledgement for each applicable year.
3. What documents should exporters maintain?
Depending on the transaction, records may include the customer contract, export invoice, shipping and customs documents, service-delivery evidence, GST returns, LUT acknowledgement, bank receipt information and supporting correspondence.
4. What happens if export proceeds are delayed?
The exporter should identify the reason for the delay, follow up with the customer, reconcile partial receipts and check the applicable GST and foreign-exchange requirements. Contact the authorised dealer bank where the applicable regulatory deadline or permitted extension needs to be confirmed.
5. Is the GST LUT deadline the same as the foreign-exchange realisation deadline?
No. They arise under different regulatory frameworks and address different requirements. The applicable GST conditions and the current RBI framework should be reviewed separately.
6. Can an exporter claim a refund after filing an LUT?
Eligible exporters may apply for a refund of accumulated input tax credit relating to exports made without payment of IGST, subject to the applicable rules, return-filing requirements and refund conditions. The GST Portal provides a specific application process for this category.
7. Who should monitor pending export realisations?
The responsibility should be assigned within the finance or accounts team, with support from sales, logistics and compliance personnel as needed. A central register with clear ownership and escalation dates helps ensure that overdue balances and approaching deadlines are not overlooked.
How FilingSuvidha Can Help ?
Organising export documentation and tracking pending payments requires coordination between accounting, GST reporting and business records. A structured process helps businesses maintain a clearer view of outstanding export invoices and supporting compliance documents.
FilingSuvidha provides accounting and compliance-related support for businesses seeking assistance with their documentation and filing processes. The appropriate support depends on the nature of the business and its specific requirements.
Contact FilingSuvidha
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Disclaimer
This article is intended for general informational purposes and does not constitute legal, tax, GST or foreign-exchange advice. Requirements can differ according to the nature of the export, the transaction date, the applicable GST provisions, RBI regulations and directions, and the exporter's circumstances. The RBI's 2026 export and import regulations took effect on 1 October 2026, so businesses should verify the current framework and any applicable transitional provisions with their authorised dealer bank or a qualified professional before acting.