RFD-01 Pre-Filing Checklist — GST Refund Readiness Across 10 Categories (FY 2025-26)
This RFD-01 Pre-Filing Checklist verifies that your GST refund application is complete and ready for submission on the GST common portal under Section 54 of the CGST Act read with Rule 89. The tool covers all 10 refund categories — exports under LUT, exports with IGST, SEZ supplies (with and without tax), inverted duty structure, deemed exports, excess cash ledger, excess tax paid, assessment-based refunds and any other category. It generates a readiness score, lists missing documents and statements, computes the 2-year limitation from category-specific relevant dates per Section 54(1), checks eligibility for the 90% provisional refund under Rule 91(2) extended to IDS by CBIC Instruction 06/2025-GST from 1 October 2025, and flags Aadhaar authentication and risk-based exclusions under Notification 14/2025-CT. Pair this with our LUT, IGST or IDS calculators to compute the actual refund amount.
RFD-01 Pre-Filing Checklist
Select your refund category, enter the period and application date, then tick each item as you confirm readiness. The tool dynamically renders the category-specific checklist on top of the common pre-filing checks, computes the limitation window, and generates a readiness scorecard showing what is still pending.
Universal Items 0/10
Exports under LUT — Specific Items 0/0
Required Documents 0/0
Section 54 & 56 Timeline
- Run readiness check to populate this list.
RFD-01 — The 10 Refund Categories Explained
Form GST RFD-01 is the unified electronic refund application introduced under Rule 89 of the CGST Rules. The portal currently supports ten distinct refund categories, each with its own statement template, documentary requirements, statutory basis and limitation rules. Selecting the correct category at filing is critical — once selected, the system locks the statement template and downstream validations.
Category-wise Quick Reference
| Category | Statement | Statutory Basis | Relevant Date |
|---|---|---|---|
| Exports under LUT (no IGST) | 3 + 3A | S.54(3)(i) + R.89(4) | Date of shipping bill / payment receipt |
| Exports with IGST paid | 2 (if RFD-01) | R.96 (auto via SB) | Date of shipping bill |
| SEZ supplies without IGST | 5 + 5A | S.54(3)(i) + R.89(4) | Date of payment / receipt by SEZ |
| SEZ supplies with IGST | 4 | S.16 IGST Act | Date of payment / endorsement |
| Inverted Duty Structure | 1A | S.54(3)(ii) + R.89(5) | GSTR-3B due date for period |
| Deemed Exports | 5B | Notif 48/2017-CT | Date of return for the period |
| Excess Cash Ledger | 7 | S.54(1) | Date of payment |
| Excess Tax Paid | 6 | S.54(1) | Date of payment |
| Assessment / Order based | — | S.54 + S.107/112 | Date of order communicated |
| Any Other Category | Custom | S.54 | Per facts of case |
The two-year limitation under Section 54(1) runs from the relevant date specific to the category. Notification 13/2022-Central Tax excluded the period from 1 March 2020 to 28 February 2022 from the limitation clock for COVID-affected periods. The relevant date for inverted duty structure was clarified to be the due date of the GSTR-3B for the period (not the end of the financial year as earlier interpreted) — a significant relaxation for taxpayers.
Statements 1A through 7 — What Goes in Each
Statements are pre-formatted templates downloaded from the GST portal, filled offline in Excel/CSV and uploaded with Form RFD-01. Each statement has a defined column structure mapped to the refund category. Filing the wrong statement or with formatting errors triggers a deficiency memo (Form RFD-03). The portal also runs server-side validation on uploaded statements before allowing submission.
Statement-by-Statement Reference
- Statement-1A (Inverted Duty Structure) — Working sheet for computing the maximum refund per Rule 89(5) formula. Columns include Inverted Turnover, Net ITC on inputs only, Adjusted Total Turnover, Tax Payable on inverted supply, ITC on input services, ratio factor, and final refund.
- Statement-2 (Export of Services with IGST) — Invoice-wise details of export services on which IGST was paid. Columns: invoice number/date, GSTIN of recipient (where applicable), taxable value, IGST amount, FIRC/BRC reference and date, place of supply, EOTC reference for advance receipts.
- Statement-3 (Exports without IGST — LUT route) — Invoice-wise zero-rated supply details. Columns: export invoice number/date, port code, shipping bill number/date, FOB value, BRC/FIRC for service exports, taxable value, currency, conversion rate.
- Statement-3A (LUT Refund Computation) — Working sheet computing Net ITC, Turnover of Zero-Rated Supplies, Adjusted Total Turnover and Maximum Refund Amount per Rule 89(4) formula. Capped at 1.5× turnover of preceding-year similar supplies (Notification 16/2020).
- Statement-4 (SEZ Supplies with IGST) — Invoice-wise details of supplies to SEZ unit/developer with IGST paid. Columns: SEZ unit/developer name, GSTIN, invoice number/date, IGST amount, endorsement reference from Specified Officer of SEZ.
- Statement-5 (SEZ Supplies without IGST) — Same structure as Statement-3 but tagged for SEZ. Endorsement from Specified Officer of SEZ confirming receipt for authorised operations is mandatory. LUT in Form RFD-11 must be active.
- Statement-5A (SEZ Refund Computation) — Working sheet computing Net ITC and Maximum Refund Amount on the same basis as Statement-3A but for SEZ supplies.
- Statement-5B (Deemed Exports) — Invoice-wise details of deemed export supplies under Notification 48/2017-CT. Columns: recipient GSTIN, invoice number/date, IGST amount, undertaking from recipient that no ITC has been availed.
- Statement-6 (Excess Tax Paid) — Details of tax paid in excess. Columns: original return reference, head-wise tax paid, refund claimed, reasons for excess (wrong head, wrong period, wrong GSTIN etc.), self-certified evidence.
- Statement-7 (Excess Cash Ledger) — Cash ledger balance details with head-wise breakdown. Simplest statement — only requires balance figures and bank account confirmation.
Common Documents Required Across All Categories
Irrespective of the refund category selected, certain documents and pre-filing actions are universal. Per Circular 125/44/2019-GST as amended by Circular 197/2023-GST and CBIC Instruction 06/2025-GST, the common documentary base includes:
- Refund Pre-Application Form filed under Services → Refunds → Refund Pre-Application — validates bank account against PFMS database and confirms it is linked to the GSTIN.
- Annexure-A (Self-Declaration) in the format prescribed by Circular 125, confirming that the incidence of tax has not been passed on to any other person and that the refund amount, if sanctioned, will not be passed on.
- Declaration of non-prosecution under Rule 89(2)(k) — applicant has not been prosecuted for any offence under the CGST Act involving tax evasion exceeding ₹2.5 crore in the preceding five years.
- Undertaking under Rule 89(2)(l) — refund will be returned to the Government if found to be inadmissible at any later stage with applicable interest and penalty.
- GSTR-1 and GSTR-3B for the tax period to which the refund relates, filed before the RFD-01 application. All returns up to the application date must also be filed.
- Electronic Credit Ledger / Cash Ledger statement downloaded from the GST portal showing the balance for the period.
- CA / CMA Certification in Annexure-2 of Circular 125 — mandatory where refund amount exceeds ₹2 lakh, except for refund of unutilised ITC under exports with payment of IGST and excess balance in cash ledger. The certificate confirms incidence of tax has not been passed on.
- Annexure-B with invoice-wise input details for accumulated-ITC categories (export under LUT, SEZ without tax, IDS).
- Validated bank account linked to the GSTIN and matched on PFMS — failure to validate triggers RFD-03 deficiency memo.
- DSC or EVC for digital signing — proprietorship and HUF can use EVC (Aadhaar OTP); companies and LLPs must use DSC.
Aadhaar authentication mandatory for provisional refund: From 1 October 2025 per Notification 14/2025-Central Tax, taxpayers not authenticated under Rule 10B are excluded from the 90% provisional refund mechanism. Complete Aadhaar authentication on the GST portal before filing RFD-01 to claim the seven-day provisional sanction benefit.
Need Help with RFD-01 Filing?
Patron Accounting's GST refund team has filed 250+ RFD-01 applications across all 10 categories. We prepare statements, Annexure-B, CA certification and complete RFD-01 submission with deficiency memo defence.
90% Provisional Refund — CBIC Instruction 06/2025-GST
The most significant procedural reform of 2025 was the introduction of system-driven 90% provisional refund through Notification 13/2025-Central Tax dated 17 September 2025 (effective 1 October 2025) read with CBIC Instruction No. 06/2025-GST. The reform — recommended by the 56th GST Council at its meeting on 3 September 2025 — addresses the chronic working-capital pain felt by exporters and inverted-duty manufacturers under the previous officer-discretion-led provisional refund mechanism.
What Changed on 1 October 2025
- System-based risk evaluation replaces manual scrutiny — Refund applications are auto-classified as low-risk or high-risk based on a system-generated risk score derived from filing history, GSTR-2B/3B reconciliation, ITC patterns and HSN-level analytics.
- Low-risk claims get 90% sanctioned within 7 days of the acknowledgement in Form RFD-02, without manual officer scrutiny. The remaining 10% is released after detailed examination culminating in the final order under Rule 92.
- Provisional refund extended to Inverted Duty Structure — Previously available only for zero-rated supplies (exports + SEZ); now extended to IDS as a trade-facilitation measure pending formal amendment of Section 54(6).
- Officer override permitted — The proper officer may, for reasons recorded in writing, decline provisional sanction in a particular case and proceed to detailed examination. Used sparingly and reasons subject to appellate scrutiny.
Who is Excluded from Provisional Refund
Notification 14/2025-Central Tax dated 17 September 2025 specifies two excluded categories per the proviso to Section 54(6):
- Aadhaar non-authenticated taxpayers under Rule 10B — must complete Aadhaar authentication on the GST portal before filing for provisional refund eligibility.
- Suppliers of high-risk specified goods — areca nuts, pan masala, tobacco, gutkha, hookah molasses and similar products with high evasion risk profile.
For excluded taxpayers and high-risk-flagged claims, the refund continues under the regular Rule 92 detailed examination route with the 60-day window applying to the full sanctioned amount.
Working capital impact: A ₹10 lakh refund claim earlier took 60-90 days for full sanction. Under the new regime, ₹9 lakh is credited within 7 days of acknowledgement. The remaining ₹1 lakh is released within 60 days. Combined with Section 56 6% interest beyond 60 days, taxpayers see ~85% liquidity improvement on average refund cycles.
Limitation Tracker — Section 54(1) and Section 56
Section 54(1) of the CGST Act prescribes a strict two-year limitation from the "relevant date" for filing any refund application. Missing the limitation results in permanent loss of the refund right — there is no mechanism for condonation under the GST law. The relevant date is category-specific and requires careful determination.
Relevant Date by Category
| Refund Category | Relevant Date | Statutory Reference |
|---|---|---|
| Export of goods under LUT or with IGST | Date of shipping bill | Explanation 2(a) to S.54 |
| Export of services under LUT | Date of receipt of payment in convertible foreign exchange or date of issue of invoice (whichever earlier) | Explanation 2(c) to S.54 |
| SEZ supplies (with or without tax) | Date of receipt of payment / date of LUT-backed supply | Explanation 2(a) to S.54 |
| Inverted Duty Structure | Due date for furnishing return for the period | Notif 13/2022-CT |
| Deemed exports | Date of return for the period in which claim arises | Notif 47/2017-CT |
| Excess cash ledger / excess tax paid | Date of payment of tax | Explanation 2(h) to S.54 |
| Refund pursuant to assessment / order | Date of communication of order | Explanation 2(e) to S.54 |
COVID Exclusion Window
Notification 13/2022-Central Tax excluded the period from 1 March 2020 to 28 February 2022 from the computation of the two-year limitation under Section 54(1). For refund claims where the relevant date or part of the limitation window falls within this period, the excluded duration is added back to extend the effective filing window. This benefit applies even to claims filed in 2026 if the underlying period was COVID-affected.
Section 54(7) and Section 56 — The 60-Day Clock
Section 54(7) requires the proper officer to issue the final refund order in Form GST RFD-06 within sixty days of receipt of the complete refund application. If the order is not issued within this window, Section 56 of the CGST Act mandates payment of simple interest at six per cent per annum from the date immediately after expiry of sixty days till the date of refund credit. Where the refund arises from an appellate order, the rate increases to nine per cent per annum under Section 56 proviso. Interest is auto-computed by the system and credited along with the refund amount.
Common Rejection Grounds — and How to Avoid Them
RFD-01 rejection typically falls into one of three buckets: documentary deficiencies (most common), eligibility failures (substantive), and procedural lapses (timing / sequence). Across 250+ RFD-01 filings, our team observes the following recurring rejection patterns.
Documentary Deficiencies (60%+ of Rejections)
- Statement upload errors — wrong template, missing columns, format mismatch with GSTR-1/3B figures, currency conversion errors in BRC/FIRC.
- Bank account not validated — PFMS validation pending, IFSC mismatch, account holder name not matching GSTIN registration name.
- Annexure-B missing or incomplete — invoice details not invoice-wise, supplier GSTIN missing, HSN classification absent.
- CA certification absent — refund exceeds ₹2 lakh in IDS / SEZ-without-tax / deemed exports / cash ledger and CA cert not uploaded.
- Endorsement from SEZ Specified Officer missing — for SEZ category, the original endorsement copy must be uploaded; system-generated copies are rejected.
Eligibility Failures (Substantive Issues)
- Restricted goods under Notification 5/2017 / 9/2022 — IDS refund claimed for textile fabrics (pre-Aug 2018) or Chapter 15 / Chapter 27 goods (post 18 Jul 2022).
- Capital goods or input services in Net ITC — only input goods qualify per VKC Footsteps SC; including services or capital goods triggers automatic reduction.
- Rate-cut accumulation, not concessional rate — IDS denied where rate inversion arose from a rate cut on the same goods, per Circular 173/05/2022.
- LUT not registered / expired — exports without IGST claimed but LUT (Form RFD-11) was not active for the period.
- BRC / FIRC not received within 1 year — for service exports, payment must be received within 1 year of invoice (extendable per RBI). Non-receipt converts the supply to taxable and refund to recovery.
Procedural Lapses
- Two-year limitation expired — application filed beyond Section 54(1) window from the relevant date.
- GSTR-1 / 3B not filed for the period — common error where applicant files RFD-01 ahead of period-end returns.
- Subsequent-period claim filed before NIL claim issue addressed — once a NIL refund is filed for a period, only that period can be reclaimed (per Circular 110/2019), provided no subsequent-period claim under same category exists.
- Incorrect category selection — IGST export refund filed via RFD-01 instead of via shipping bill (Rule 96 auto), or LUT route filed with payment of IGST.
Deficiency Memo (RFD-03) — How to Respond
The proper officer issues a deficiency memo in Form GST RFD-03 within fifteen days of filing if the application is found incomplete or contains errors. The memo specifies the deficiencies and gives the applicant an opportunity to file a fresh application after rectification. Critically, the original application is treated as non-existent — the two-year limitation continues to run while the rectification is pending.
RFD-03 Response Workflow
- Acknowledge promptly — Login to the GST portal, navigate to Services → Refunds → Track Application Status, and acknowledge the RFD-03 memo within 15 days of issue.
- Identify each deficiency — RFD-03 enumerates specific items: missing statements, calculation errors, document defects, ledger reconciliation gaps, validation failures.
- Rectify and re-prepare — Correct the underlying data in GSTR-1/3B if needed (via amendment in subsequent return), regenerate statements, re-upload Annexure-B with complete invoice details, fix bank validation through the Refund Pre-Application Form.
- File a fresh RFD-01 — The original ARN is closed; a new application with a new ARN must be filed. Reference the earlier ARN in the application narrative.
- Track limitation — Section 54(1) two-year clock does not stop. If the original application was close to limitation, the rectified fresh filing may itself become time-barred. File rectified application well within the window.
RFD-08 vs RFD-03 — Different Triggers
RFD-03 is for procedural / documentary deficiencies issued before the substantive scrutiny. RFD-08 is the show-cause notice issued after substantive scrutiny when the proper officer proposes to reject the refund in part or in full. RFD-08 must be replied to within 15 days through Form GST RFD-09 with detailed submissions and supporting documents. Failure to reply or unsatisfactory reply leads to rejection through Form GST RFD-06.
RFD-01 Filing Steps on the GST Portal
The actual filing of RFD-01 on gst.gov.in is a sequential process. Each step has its own validation gate; an error at any step prevents progression. The end-to-end portal walkthrough takes 30-60 minutes for clean cases.
Step-by-Step Portal Workflow
- Pre-requisite: File GSTR-1 and GSTR-3B for the period. Verify all returns up to the application date are filed with no pending GSTR-3B.
- Refund Pre-Application Form — Services → Refunds → Refund Pre-Application Form. Validate bank account against PFMS. Wait for PFMS confirmation (1-2 days).
- Access RFD-01 — Services → Refunds → Application for Refund. Choose financial year and quarter/month.
- Select Refund Type from the dropdown — picks the right statement template and downstream validations.
- Enter refund amount head-wise — IGST, CGST, SGST/UTGST, Cess. Constrained by electronic credit ledger (for ITC refunds) or cash ledger (for cash refund).
- Upload Statement in the prescribed template — system validates structure and computes maximum refund.
- Upload supporting documents — Annexure-A self-declaration, Annexure-B (where applicable), CA certificate (where applicable), category-specific evidence.
- Confirm bank account from the Pre-Application validated list.
- Save and preview — system generates a draft RFD-01 PDF for review. Save and revisit if needed.
- Submit with DSC or EVC — proprietorship/HUF can use EVC; companies/LLPs must use DSC. ARN is generated immediately.
- Track ARN — Services → Refunds → Track Application Status. Acknowledgement (RFD-02) issued within 15 days. Provisional sanction (RFD-04) for low-risk claims within 7 days from October 2025.
Two-stage flow under new regime: Post-1 October 2025, the system first issues RFD-02 (acknowledgement), then automatically RFD-04 (provisional 90% sanction) for low-risk claims, then RFD-06 (final order with remaining 10%). Applicants should track both the provisional sanction milestone (7 days) and the final order milestone (60 days) for cash flow planning.