GST Compliance Declaration | CGST Act 2017 & Rule 96A

A GST compliance declaration is a self-certification, made on letterhead and signed by an authorised signatory, recording facts that GST law or commercial practice requires a business to confirm in writing. The most common variants state that the declarant holds a valid GSTIN, that it files its returns in Form GSTR-1 and Form GSTR-3B on time, that it has opted into or out of the composition scheme under Section 10 of the CGST Act, 2017, that it falls below the e-invoicing threshold, or that it is unregistered because its aggregate turnover sits under the limits set by Section 22. Exporters know the format in its statutory form: the Letter of Undertaking filed in Form GST RFD-11 under Rule 96A of the CGST Rules, 2017, which permits zero-rated supplies without upfront payment of IGST.

The declaration differs from a general affidavit sworn under the Oaths Act in one practical respect: it does not normally require attestation before a notary or magistrate, because it operates as a commercial representation rather than judicial evidence. It still binds the signatory. A buyer who relies on a false GST declaration can recover denied input tax credit contractually, and the department can treat a false statement as an offence. The document is short, rarely more than two pages, but every line in it has fiscal consequences.

The governing architecture is the CGST Act, 2017 together with the mirror SGST Acts of each State and the IGST Act, 2017 for inter-state and export transactions. Several provisions push businesses toward written declarations. Section 22 and Section 24 fix who must register, so an unregistered vendor confirming its sub-threshold status is effectively declaring that neither provision captures it. Section 10(4) prohibits a composition taxpayer from collecting tax, and Rule 49 obliges it to issue a bill of supply carrying the words "composition taxable person, not eligible to collect tax on supplies"; buyers routinely demand a standalone declaration repeating that status before booking the first invoice. On the export side, Section 16 of the IGST Act classifies exports and supplies to SEZ units as zero-rated supplies, and Rule 96A makes the undertaking in Form GST RFD-11 the condition for shipping without IGST. The exporter undertakes to complete export of goods within three months of the invoice date, to realise service proceeds within one year, and to pay the tax with interest at 18 per cent under Section 50 if either commitment fails.

False declarations carry teeth. Section 122(1) penalises the furnishing of false information, and the general penalty under Section 125 reaches Rs. 25,000 under each of the central and state enactments even where no specific penalty applies. Large evasion can trigger prosecution under Section 132. The full text of the statute is available through the official India Code repository hosting the Central Goods and Services Tax Act, 2017, which remains the reference version practitioners cite. A declaration is not a formality: it is a representation the department and your counterparties are entitled to hold you to.

The most frequent trigger is vendor onboarding. Listed companies and large buyers will not release a purchase order until the supplier certifies its GSTIN, its return-filing regularity and its e-invoicing status, because a defaulting supplier puts the buyer's input tax credit at risk under Section 16(2)(c). The second scenario is the composition dealer explaining to clients why its bills of supply show no tax; without a written declaration, accounts teams flag the invoice and payment stalls. Exporters need the format every financial year, since the LUT filed in Form GST RFD-11 lapses on 31 March and a fresh undertaking must be in place before the first export invoice of the new year. A fourth situation is the unregistered supplier confirming that its turnover sits below the registration threshold, a declaration buyers archive to justify procurement without a tax invoice.

Two edge cases deserve attention. A business crossing the e-invoicing turnover limit mid-relationship must issue a corrective declaration promptly, because invoices raised without an IRN after the threshold date are not valid tax invoices under Rule 48(5) and the buyer's credit evaporates with them. And entities supplying through e-commerce operators are often asked to declare their registration status so the operator can apply the correct TCS treatment under Section 52; treating that request casually delays settlement of marketplace payouts. In each case the declaration sits on file with other regulatory notices and compliance formats the business maintains for audit.

• The identification block records the legal name, trade name, GSTIN or its absence, principal place of business and the State of registration. Buyers cross-verify these details against the GST portal, so the template mirrors the registration certificate field by field rather than relying on informal trading names.
• The declaration of registration status states whether the declarant is a regular taxpayer, a composition taxpayer under Section 10, or unregistered with turnover below the Section 22 threshold. The wording tracks the statutory language, because paraphrased status descriptions are the first thing a tax officer questions.
• The return-filing and compliance confirmation certifies that GSTR-1 and GSTR-3B are filed within due dates and that no proceedings for cancellation of registration are pending. This is the clause that protects the recipient's input tax credit and the one most heavily negotiated.
• The e-invoicing applicability statement declares whether aggregate turnover has crossed the notified threshold and, if so, that all B2B invoices carry a valid IRN and QR code under Rule 48(4).
• The indemnity undertaking commits the declarant to make good any tax, interest or penalty the recipient suffers because a statement in the declaration proves false. It converts a compliance courtesy into an enforceable contractual promise.
• The authorised signatory attestation closes the document with name, designation, date and place. Where the declarant is a company, the signatory's authority should trace back to a board resolution under Section 179 of the Companies Act 2013, and the template prompts for that reference.

Maharashtra hosts the largest concentration of registered taxpayers, and its state machinery is correspondingly active: the Maharashtra GST Department runs frequent return-scrutiny drives, so declarations certifying filing regularity are checked against actual portal data more often than elsewhere. Businesses with units in Mumbai and Pune under a single PAN hold separate GSTINs per State, and a declaration must name the specific registration it covers, not the group. The intra-state e-way bill threshold of Rs. 1 lakh, higher than the national Rs. 50,000 default, also shapes the logistics declarations Maharashtra suppliers attach to despatches.

Delhi presents the classic multi-jurisdiction problem: a single business often bills from Delhi while warehousing in Haryana or Uttar Pradesh, and buyers ask for declarations confirming which GSTIN will appear on invoices for each supply. Delhi's enforcement wing has been aggressive on fake invoicing networks, which is why Delhi counterparties increasingly insist on the indemnity clause and verify the declarant's filing history before releasing credit terms.

Karnataka and its Bengaluru technology corridor generate the bulk of service-export declarations. Software exporters file the RFD-11 undertaking annually and furnish parallel declarations to clients confirming zero-rated treatment of supplies to SEZ units under Section 16 of the IGST Act. The Karnataka Authority for Advance Rulings has produced several divergent rulings on intermediary services, so exporters there often annexe a declaration of the precise nature of services to pre-empt classification disputes.

Gujarat combines heavy goods exports with a dense MSME base. Manufacturers in Ahmedabad and Surat lean on the LUT route to keep working capital free, and their buyers commonly request composition-status declarations from job workers in the textile chain, where the Section 10 scheme is widespread. Gujarat's officers are exacting on the three-month export window under Rule 96A; a declaration there should be backed by shipping bill discipline, not optimism.

You start by selecting the capacity in which the declaration is made: regular taxpayer, composition dealer, unregistered supplier or exporter furnishing an undertaking. The form then adjusts the statutory recitals, pulling in Section 10 language for composition status or Rule 96A commitments for exports. Next you enter the identification details exactly as they appear on the registration certificate, including the 15-character GSTIN, the legal name as per PAN and the principal place of business. The tool prompts for the addressee, because a declaration to a buyer reads differently from an undertaking addressed to the jurisdictional officer. You then confirm the compliance statements that apply, strike the ones that do not, and complete the signatory block with designation and supporting authority. Businesses that supply under a written contract often pair the declaration with a service agreement drafted under the Indian Contract Act so the indemnity in both documents reads consistently. The finished declaration downloads in Word and PDF; print it on letterhead, sign in ink or affix a DSC, and keep a copy in your GST file for the financial year.

The error seen most often in practice is the stale declaration. A vendor certifies return-filing regularity in April, defaults in August, and never issues a corrective statement; when the buyer's credit is questioned under Section 16(2)(c), the old declaration becomes evidence of misrepresentation rather than protection. Treat the document as a living certificate and refresh it whenever status changes, especially on crossing the e-invoicing threshold or switching out of the composition scheme. A second recurring fault is the unsigned or wrongly signed declaration: an accounts executive signing without authority gives the recipient nothing enforceable, and companies should always cite the resolution empowering the signatory.

Exporters make their own characteristic mistakes. Some raise export invoices before the fresh financial-year LUT is in place, then discover that every invoice in the gap attracts IGST with 18 per cent interest. Others copy a goods-export undertaking for a services business and miss the one-year realisation condition that applies to service proceeds. Finally, unregistered suppliers frequently declare sub-threshold turnover by looking at a single GSTIN's billing instead of aggregate turnover across all States under one PAN, the measure Section 2(6) actually prescribes. Compute the aggregate figure before signing, because an honest mistake on turnover still voids the declaration's protective effect.