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GST Refund New Rules 2026: What Has Changed and What Is Still Pending

In force: the substituted Rule 91(2) (from 01.10.2025) requires the provisional refund order in RFD-04 within 7 days of acknowledgement, based on system risk evaluation...

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September 30, 2026
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Oct 2, 2026
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Last updated: October 2026Applies to: FY 2026-27Verified against: Government sources

GST refund law has moved a lot in the past year. Some changes already decide how your claim is processed today; others are in the Finance Act 2026 but do not apply until the government notifies a start date. Mixing up the two is the most common error in current refund advice. This page separates them, as on 30 September 2026.

At a glance

ChangeStatus on 30.09.2026Effect on refunds
Rule 91(2) substituted: RFD-04 within 7 days, risk-basedIn force from 01.10.2025Quicker provisional refund for zero-rated claims that clear system risk checks
IGST s.13(8)(b) omitted (intermediary services)In force from 30.03.2026Intermediary services to foreign clients can be exports and claim refund
GST 2.0 rate structure (5%, 18%, 40%)In force from 22.09.2025Rate cuts have left fresh inverted-duty credit in many sectors
s.54(6) extended to inverted-duty refunds (Finance Act 2026)Enacted; awaiting notification90% provisional refund would become available for inverted duty
s.54(14) ₹1,000 minimum removed for exports of goods with payment of tax (Finance Act 2026)Enacted; awaiting notificationSmall IGST refunds on exports would no longer be dropped

For how these change a claim you are about to file, our GST refund hub sets out each refund category.

1. Provisional refund in seven days, on system risk (in force)

Section 54(6) allows 90% of a zero-rated refund claim on a provisional basis. Rule 91(2), as substituted w.e.f. 01.10.2025, now says the proper officer, on the basis of identification and evaluation of risk by the system, shall issue the RFD-04 order within seven days from the acknowledgement under Rule 90.

Two limits remain:

  • A proviso lets the officer, for reasons recorded in writing, decline the provisional refund and proceed to the final order under Rule 92.
  • Rule 91(1) still bars provisional refund where the applicant was prosecuted, in the five years before the claim period, for an offence involving tax evasion above ₹250 lakh.

In practice, a clean claim that matches returns and GSTR-2B has the best chance of clearing the system checks. Our LUT export refund service prepares claims with that in mind.

2. Intermediary services: now exportable (in force)

Section 13(8)(b) of the IGST Act placed the supply of intermediary services at the location of the supplier. So an Indian intermediary serving a foreign principal could not treat the service as an export. The Finance Act 2026 omitted clause (b) w.e.f. 30.03.2026. Intermediary services now follow the default rule in s.13(2), generally the recipient's location.

Where the s.2(6) IGST export conditions are met, including receipt of payment in convertible foreign exchange (or in INR where RBI permits), the supply is zero-rated. That means LUT and an ITC refund under Rule 89(4), or export with IGST paid and a refund of that tax. This applies to supplies on or after 30.03.2026 only. Details are in intermediary omitted 2026: GST refund for exporters and intermediary services place of supply.

3. GST 2.0 and inverted duty (in force)

From 22.09.2025, the main slabs are 5% and 18%, with a 40% rate for specified goods. Where output rates came down but inputs did not, credit is now piling up. That is a Rule 89(5) refund under s.54(3)(ii), subject to the usual limits: no refund where output is nil-rated or fully exempt, input services and capital goods out of Net ITC, and the goods notified as ineligible. Check the current rate schedule for your goods before assuming a claim. See ITC accumulation after GST 2.0 rate cuts. Our inverted duty refund service handles these claims.

4. Finance Act 2026 amendments awaiting notification

s.54(6), provisional refund for inverted duty. The Finance Act 2026 extends provisional refund to refund of unutilised ITC under s.54(3) first proviso clause (ii), that is, inverted-duty claims. The ICAI Background Material (July 2026) records it as inserted w.e.f. a date yet to be notified. Until then, inverted-duty claims get no RFD-04; they go to the final order within 60 days.

s.54(14), ₹1,000 minimum. Today, no refund under s.54(5) or (6) is paid if the amount is under ₹1,000, applied per tax head (Circular 125/44/2019-GST). The Finance Act 2026 adds an exception for goods exported out of India with payment of tax. The same source marks it not yet notified. Until it is, small refunds still fall below the limit.

Our advice: these amendments are enacted, but check the notification status on the CBIC site before relying on them in a claim.

5. Recent changes still worth knowing

ChangeDateWhat it means
Rule 94(2): applicant-caused delays excluded from interest01.10.2023Reply time beyond 15 days of RFD-08, and bank-detail delays, reduce the interest period
Rule 96(10) omitted08.10.2024The old bar on IGST-paid export refunds for exporters using certain import exemptions is gone
Rule 89(4A)/(4B) omitted; ATT and Net ITC wording aligned08.10.2024Notification 20/2024-CT
s.54(15): no refund where goods exported are subject to export duty01.11.2024Applies to both ITC refund and IGST-paid routes
GSTAT pre-deposit: further 10%01.11.2024Relevant if appealing a refund rejection
Gemini Edibles: SLP dismissed09.05.2025Entitlement to inverted-duty refund attaches when credit accumulates, not when the claim is filed

Interest on late refunds is unchanged at 6% p.a., and 9% where the refund flows from an appellate or court order; see GST refund interest calculation.

Need help applying the 2026 changes to your claims?

Intermediary exporters now have a refund route, and inverted-duty claims from the GST 2.0 rate cuts are piling up. We check which rule applies to which period and file accordingly. Run a first figure in the GST refund calculator, then talk to us through the GST refund hub.

Key takeaways

  • Provisional refund for zero-rated claims is now due within 7 days, on system risk evaluation (from 01.10.2025).
  • Intermediary services to foreign clients can be exports for supplies on or after 30.03.2026.
  • GST 2.0 rate cuts have created fresh inverted-duty refund claims.
  • Provisional refund for inverted duty and the ₹1,000 carve-out for exports with tax are enacted but await notification.
  • Always check the effective date of an amendment against the period of your claim.

Read next

Disclaimer: Positions stated as on 30 September 2026, based on the CGST Act and Rules as amended, the Finance Act 2026, and the ICAI Handbook on Refunds under GST (January 2026). Verify current notifications before filing.

Quick recapKey facts & short answers

Key Facts About GST Refund New Rules

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What are the new GST refund rules in 2026?

In force: the 7-day risk-based provisional refund (Rule 91(2), from 01.10.2025) and the omission of the intermediary place-of-supply rule (from 30.03.2026). Enacted but awaiting notification: provisional refund for inverted duty and the ₹1,000 carve-out for exports with tax.

Is provisional refund available for inverted duty refunds now?

Not yet. The Finance Act 2026 extends s.54(6) to inverted-duty refunds, but only from a date to be notified.

A clean record is built one small filing at a time, not in the week before an inspection.

— TaxClue Compliance Desk

GST Refund New Rules: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

People also ask

Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

In force: the 7-day risk-based provisional refund (Rule 91(2), from 01.10.2025) and the omission of the intermediary place-of-supply rule (from 30.03.2026). Enacted but awaiting notification: provisional refund for inverted duty and the ₹1,000 carve-out for exports with tax.

Not yet. The Finance Act 2026 extends s.54(6) to inverted-duty refunds, but only from a date to be notified.

Only for exports of goods with payment of tax, and that amendment awaits notification. The limit applies per tax head otherwise, and never applied to excess cash-ledger balance.

Yes, for supplies on or after 30.03.2026 that meet the export-of-services conditions.

No. The Rule 89(5) formula is the same; the rate changes simply created new inverted-duty credit for many businesses.

No. It remains 6% p.a., and 9% where the refund arises from a final appellate or court order.