Statement 5 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Supplies to an SEZ unit or developer for authorised operations are zero-rated. If you supply without charging IGST under LUT or bond, credit builds up in your ledger and you claim it back in RFD-01. Statement 5 is the invoice statement for that claim. It needs one thing an export claim does not: the SEZ officer's endorsement.
Statement 5 is filed with RFD-01 for a refund of unutilised ITC on supplies to an SEZ unit or developer without payment of tax. It comes from Rule 89(2)(d) (goods: invoice number and date plus the endorsement evidence) and Rule 89(2)(e) (services: invoices, endorsement and proof of payment by the SEZ recipient). Statement 5A carries the Rule 89(4) calculation. If you supplied with payment of IGST, the statement is Statement 4. You also declare under Rule 89(2)(f) that no tax was collected from the SEZ.
Which SEZ statement applies to you
| Your situation | Statement | Rule | Calculation statement |
|---|---|---|---|
| Supplied to SEZ under LUT/bond, claiming ITC | Statement 5 | 89(2)(d) and (e) | Statement 5A under Rule 89(4) |
| Supplied to SEZ charging IGST, claiming the tax paid | Statement 4 | 89(2)(d) and (e) | Not applicable |
| Deemed export supplies (EOU, advance authorisation) | Statement 5B | 89(2)(g) | Not applicable |
Both SEZ routes also need the Rule 89(2)(f) declaration, the section 16(2)(c) undertaking, and the Rule 89(2)(l) self-declaration or 89(2)(m) certificate as the Handbook's checklist lists them. The Rule 89(4) route also takes the declaration under the proviso to section 54(3).
Choosing between LUT and payment of IGST affects cash flow as much as paperwork. It is covered in SEZ supplier GST refund: with payment vs LUT. If you already have supplies stuck without endorsements, our SEZ supplies refund service can sort out the evidence before filing.
What Rule 89(2)(d) and (e) require
We have not reproduced a portal column layout, because the RFD-01 screen changes with GSTN updates. The particulars the law requires are:
| Supply | Rule | Required in the statement |
|---|---|---|
| Goods to SEZ | 89(2)(d) | Number and date of invoices (as provided in Rule 46), with evidence of the endorsement under the proviso to Rule 89(1) |
| Services to SEZ | 89(2)(e) | Number and date of invoices, the endorsement evidence, and details and proof of payment made by the SEZ recipient to the supplier for authorised operations |
Two points stand out:
- Endorsement comes first. Rule 89(1) says a goods supplier files the refund only after the goods have been admitted in full into the SEZ for authorised operations, as endorsed by the specified officer of the Zone. For services, the evidence of receipt must be endorsed. No endorsement means no valid refund.
- Services need payment proof. Unlike goods, the services statement must show the SEZ recipient has actually paid.
The GSTR-1 and GSTR-3B link
The Handbook's procedure for SEZ refunds starts with the returns:
- Report SEZ invoices in Table 6B of GSTR-1, choosing "with payment" or "without payment" invoice by invoice.
- Disclose the value, and IGST where paid, under zero-rated supplies in Table 3.1(b) of GSTR-3B.
The portal validates the refund against these entries. An SEZ invoice reported in Table 4 as a domestic B2B supply, or a 3.1(b) figure lower than the claim, will block the application. Fix the return first, through amendment, before you build Statement 5.
Statement 5A: the refund calculation
Statement 5A uses the same zero-rated formula as exports:
Refund = (Zero-rated turnover of goods + zero-rated turnover of services) × Net ITC ÷ Adjusted Total Turnover
Illustration (round figures). In a quarter a supplier makes SEZ supplies of goods under LUT of ₹40 lakh and domestic taxable supplies of ₹60 lakh. Net ITC (inputs and input services) is ₹6 lakh. Adjusted total turnover = ₹100 lakh. Refund = 40 × 6 ÷ 100 = ₹2.4 lakh. If endorsement is pending on a ₹10 lakh consignment, leave it out of Statement 5 and the zero-rated turnover in 5A. Claim it in a later application once endorsed, within the two-year limit.
Check your numbers with the GST refund calculator before you file.
Provisional refund on SEZ claims
SEZ supplies are zero-rated, so section 54(6) provisional refund of 90% is available. Since 01.10.2025, substituted Rule 91(2) requires the order in RFD-04 within seven days of acknowledgement, on the basis of system-based risk evaluation. The officer may, for reasons recorded, decline provisional refund and proceed to a final order. The Handbook's supporting-documents list asks for a non-prosecution self-declaration under Rule 91(1) to avail provisional refund. The balance is settled in RFD-06.
Common Statement 5 errors
- Endorsement missing or partial. Goods not admitted in full, or endorsement on only some invoices.
- Wrong statement. Using Statement 5 for supplies on which IGST was charged. That belongs in Statement 4.
- Table 6B mismatch. Invoice numbers or values differ from GSTR-1.
- Tax collected from the SEZ. It contradicts the Rule 89(2)(f) declaration and defeats the claim.
- Inward side unsupported. Annexure B invoices not in GSTR-2B. Following a 2026 GSTN advisory, Annexure B for SEZ-without-payment claims is filed through GSTN's Excel offline utility as a JSON upload, not as a PDF. See our note on the refund offline utility.
The sister statements are covered in Statement 3 for LUT exports and Statement 1A for inverted duty.
Need help with an SEZ refund?
SEZ refunds depend on paperwork from someone else: the Zone's specified officer and your SEZ customer. If endorsements are pending, the SEZ customer disputes a payment, or a claim came back with a deficiency memo, we can assemble the evidence, rebuild Statement 5 and 5A, and follow the claim through. See our GST refund service for SEZ supplies.
Key takeaways
- Statement 5 is for SEZ supplies without payment of tax (ITC refund). Statement 4 is for SEZ supplies with payment of IGST.
- Rule 89(2)(d) (goods) needs invoices plus endorsement evidence. Rule 89(2)(e) (services) also needs proof of payment by the SEZ recipient.
- File only after goods are admitted in full into the SEZ and endorsed by the specified officer.
- Statement 5A applies the Rule 89(4) formula. Leave out unendorsed supplies until they are endorsed.
- SEZ claims qualify for 90% provisional refund, now issued within seven days on system risk evaluation.
Read next
- Refund of tax on supplies to SEZ and the endorsement
- GST refund for SEZ units and developers: special process
- GST refund forms list: RFD-01 to RFD-11
- Rule 89(2): documentary evidence for a refund claim
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.