GIFT City BLUT Explained: What This Complete Compliance Guide Actually Covers
Anyone setting up a business inside GIFT IFSC eventually runs into this term. GIFT City BLUT — the Bond-cum-Legal Undertaking — is the compliance document an SEZ unit executes after its Letter of Approval is issued. It records the unit’s undertakings and obligations under the SEZ framework, backed by a bond.
It comes after the LOA in the setup sequence, and it is worth being precise about what it is not. A GIFT City BLUT is not the LOA. It is not the registered lease deed for a unit’s premises. And it is not a sector-specific IFSCA licence — a fund manager or a bank still needs its own regulatory authorisation separately.
This guide covers what BLUT actually is, why it exists, what Form-H contains, how it is executed under the current 2026 electronic process, and what happens once it is approved. It sits inside the same compliance cluster as GIFT City SEZ, GIFT City PLOA, and GIFT City LOA on this site — read those first if the sequence itself is unfamiliar.
What Is GIFT City BLUT?
A Bond-cum-Legal Undertaking is a combined instrument — part bond, part undertaking — that an SEZ unit executes under Rule 22 of the SEZ Rules, 2006. It is prescribed in a specific format, Form-H, set out in the SEZ Rules themselves.
For GIFT IFSC units specifically, the Administrator (IFSCA) exercises the powers of the Development Commissioner under the SEZ Act. That means BLUT approval for a GIFT City unit runs through the Administrator’s office, working alongside the Specified Officer of Customs, rather than through a conventional SEZ Development Commissioner elsewhere in the country.
What the GIFT City BLUT actually records is straightforward at a conceptual level: it sets out the unit’s undertakings and compliance obligations under the SEZ framework, and it does so against a defined bond value. It is a regulatory and compliance instrument, not a property document and not an operating licence.
Why Is BLUT Required?
The BLUT exists because an SEZ unit operates under a distinct set of obligations the moment its LOA is issued — duty treatment, reporting, and adherence to its approved scope of activity among them. The undertaking is how the unit formally commits to those obligations in writing, on record with the SEZ authority.
The bond component sits alongside the undertaking rather than replacing it. It is not a punitive instrument dreamed up to make setup harder — it is the standard mechanism SEZ Rules use to back a unit’s compliance commitment, calculated against supporting figures the unit provides at execution.
None of this creates rights on its own. A GIFT City BLUT does not establish a unit’s premises — the lease deed does that. It does not authorise the unit’s operations — the LOA already did that, and the BLUT follows it. And it does not amount to sector-specific IFSCA registration for banking, fund management, insurance, or any other regulated activity. Those stay separate.
Where BLUT Fits After the LOA
The setup sequence, at a glance, runs: PLOA, then LOA, then BLUT, then Lease Deed, then Eligibility Certificate, then Commencement of operations.
The PLOA confirms premises are provisionally reserved by the developer. The LOA is the SEZ authorisation that lets the entity actually operate as a unit, issued under Rule 19 after Unit Approval Committee review. The BLUT is the compliance bond and undertaking covered in this article. The Lease Deed is the registered document confirming the same premises, due within six months of the LOA date. The Eligibility Certificate, issued alongside an approved BLUT, is the document used in relation to applicable Gujarat state-level exemptions. Commencement is the formal start of approved operations, intimated to the Administrator.
One caution worth flagging: this list reads as a strict sequence, but current IFSCA process material makes clear several of these post-LOA steps can run in parallel rather than waiting on each other one at a time. A unit working toward its Lease Deed does not necessarily need to wait for every other filing to close first. Confirm the current expected order with IFSCA or the SEZ Online portal for your specific case rather than assuming a rigid queue.
Form-H: What Does the BLUT Contain?
Form-H is the prescribed format for the Bond-cum-Legal Undertaking under the SEZ Rules. It is a structured document rather than a free-form letter, and its major components are worth understanding without reproducing the entire form here.
It records the unit’s identity and its SEZ address — the exact entity name and premises location as they appear in the unit’s SEZ records. It names the obligor and the authorised signatory executing the undertaking on the unit’s behalf. It sets out the bond value, along with the supporting calculation sheet behind that figure. And it contains the undertakings themselves — the specific compliance commitments the unit is making to the SEZ authority.
Consistency across these fields matters more than it might seem. If the entity name on the BLUT does not match the name on the LOA, or the SEZ address differs from what is on record, or the bond amount does not tie back to its supporting calculation, that inconsistency is exactly the kind of thing that surfaces during review and slows approval down.
This article does not attempt to state a universal bond amount or a fixed percentage that applies to every unit. Bond value calculation depends on figures specific to the unit and the current guidance in force at the time of execution. Confirm the applicable calculation methodology directly through IFSCA’s published guidance rather than relying on a number quoted elsewhere.
How to Execute GIFT City BLUT Under the Current 2026 Process
The practical steps for executing a GIFT City BLUT today run roughly as follows.
First, the unit prepares the BLUT in Form-H, along with its supporting documents and the bond-value calculation sheet behind the figure it is declaring.
The execution mechanism itself changed materially in 2026. Under Instruction No. 123, dated 23 February 2026, issued by the Ministry of Commerce, a BLUT may now be executed electronically — as an e-BLUT — including through e-stamp or another digital mechanism, and it may be signed using a Digital Signature Certificate. This instruction superseded the earlier Instruction No. 02 of 24 March 2006, and with it, the older requirement to execute the BLUT on physical non-judicial stamp paper, notarised by a Notary Public, was done away with.
Filing itself runs through the SEZ Online portal, using the New LUT request route within that system’s legal undertaking module. That module is where a unit submits its BLUT for review by the relevant office.
Approval follows the joint framework the SEZ Rules already contemplate for this instrument — sign-off by the Specified Officer of Customs and the Administrator (IFSCA), as applicable to the unit’s circumstances. For the current, authoritative statement of this approval process specific to GIFT IFSC units, IFSCA’s Public Notice No. 06/2026-27, dated 12 August 2026, is the relevant source to check.
None of this removes the need for accuracy on the unit’s side. A BLUT filed with mismatched details or an unsupported bond figure does not move faster simply because the filing itself is electronic.
e-BLUT: What Changed in 2026?
It is worth giving the 2026 shift its own space, because a fair amount of older material still describes the previous process as current.
Before Instruction No. 123, a BLUT for an SEZ unit — GIFT IFSC units included — had to be executed on non-judicial stamp paper and notarised before it could be submitted for approval. That meant physical paperwork, a notary visit, and the logistics that come with both, which was a genuine friction point for entities setting up from outside Gujarat or outside India entirely.
Under the current framework, that physical execution step is no longer the requirement. The BLUT may be executed electronically, with e-stamp or another digital mechanism replacing the earlier physical execution process, while the requirement for notarisation has been dispensed with.
The more accurate way to describe this change is electronic execution and online approval, rather than claiming the entire GIFT City BLUT process has become universally paperless in every respect. Supporting documentation, the bond calculation sheet, and the SEZ Online filing itself still require care and completeness — the shift is in how the undertaking is executed and submitted, not a removal of the underlying compliance review. Anyone consulting an older SEZ or GIFT IFSC guide should treat any reference to physical stamp paper or notarisation as outdated against the current position.
BLUT Approval: Who Approves It and What Happens Next?
Once a GIFT City BLUT is executed and filed, approval runs through the joint framework the SEZ Rules set out — the Specified Officer of Customs and the Administrator (IFSCA), as applicable to the specific unit and filing.
After approval, it is worth checking the approved BLUT against a short list before filing it away: the entity name, the SEZ address, the obligor and signatory details, the bond amount, the relevant dates, and any other material particulars recorded on the document. Any discrepancy caught at this stage is far easier to correct than one discovered later during a compliance review.
The approved GIFT City BLUT should then be retained in the unit’s own compliance records, alongside its LOA and, in due course, its registered Lease Deed and Eligibility Certificate. This is the document a unit will want readily available if its SEZ file is ever reviewed.
BLUT vs LOA vs Lease Deed vs Eligibility Certificate
These four documents get referenced together often enough that it helps to see them side by side.
| Document | Main Purpose | Stage | What It Does Not Mean |
|---|---|---|---|
| PLOA | Premises/Allotment | Before SEZ application | Not final SEZ approval |
| LOA | SEZ unit approval | Approval stage | Not a substitute for sector-specific IFSCA authorisation |
| BLUT | SEZ undertakings / compliance bond | Post-LOA compliance | Not a lease or licence |
| Lease Deed | Registered premises document | Premises compliance | Not the LOA |
| Eligibility Certificate | Applicable tax-exemption eligibility | Post-LOA compliance | Not the BLUT or LOA |
None of these four should be treated as interchangeable. Each is issued by a different party, at a different stage, and each answers a different question about the unit’s SEZ standing.
Common Mistakes
- Relying on outdated guidance that still describes the physical stamp-paper and notarisation process as current.
- Treating the BLUT as equivalent to the LOA, when it is a distinct, later compliance step.
- Entering an incorrect entity name or SEZ address on the Form-H filing.
- A bond amount that does not match the supporting calculation sheet or other filed documents.
- An incorrect or unauthorised signatory executing the undertaking on the unit’s behalf.
- Assuming e-BLUT removes compliance scrutiny entirely, when the underlying review of details still applies.
- Failing to retain a copy of the approved BLUT in the unit’s own compliance file.
- Ignoring later changes to the unit’s structure or premises that could affect its existing compliance position.
What Happens After BLUT?
Once the GIFT City BLUT is approved, the remaining steps in the sequence come into view: the registered Lease Deed for the unit’s approved premises, the Eligibility Certificate that follows an approved BLUT, and any activity-specific requirements such as an Import Export Code, GST registration, or the unit’s own IFSCA regulatory authorisation.
Commencement of operations, and the intimation of that date to the Administrator, sits at the end of this stretch. Each of these steps has its own procedure and its own documentation, covered in dedicated guides on GIFT2Invest.com — including the existing articles on GIFT City PLOA, GIFT City LOA, and the GIFT City Lease Deed, with an Eligibility Certificate and Commencement of Operations guide to follow.
Wrapping Up: GIFT City BLUT in the Bigger Picture
The GIFT City BLUT is an important post-LOA compliance step, not the entire operating approval for a unit. It records the SEZ undertakings a unit is making, backed by a bond, and it sits distinctly apart from the LOA, the Lease Deed, and any sector-specific IFSCA registration.
The 2026 shift to electronic execution — under Instruction No. 123 — changed how a GIFT City BLUT gets executed and filed, replacing the older physical stamp-paper and notarisation process with electronic mechanisms. It does not reduce the need for accurate, consistent details across the filing.
For the stages on either side of the GIFT City BLUT, the existing guides on GIFT City SEZ, GIFT City PLOA, GIFT City LOA, and the GIFT City Lease Deed cover the rest of the setup sequence in more depth. GIFT2Invest.com will add dedicated Eligibility Certificate and Commencement of Operations guides to complete this compliance series.
Frequently Asked Questions About GIFT City BLUT
What is BLUT in GIFT City?
It is the Bond-cum-Legal Undertaking an SEZ unit executes under Rule 22 of the SEZ Rules, recording its compliance undertakings to the SEZ authority against a defined bond value. Every GIFT IFSC unit is also an SEZ unit and falls under this requirement.
Is BLUT Mandatory for Every GIFT IFSC Unit?
Yes. Because every IFSCA-approved GIFT IFSC unit is automatically an SEZ unit under the SEZ Act, the BLUT requirement under Rule 22 applies to units generally, following the LOA stage.
What Is Form-H?
Form-H is the prescribed format for the Bond-cum-Legal Undertaking under the SEZ Rules. It covers the unit’s identity and SEZ address, the obligor and signatory, the bond value and its calculation, and the undertakings the unit is making.
Who Approves BLUT?
Approval runs jointly through the Specified Officer of Customs and the Administrator (IFSCA), consistent with the framework set out in the SEZ Rules and current IFSCA guidance for GIFT IFSC units.
Can GIFT City BLUT Be Executed Electronically?
Yes. Under Instruction No. 123 dated 23 February 2026, a BLUT may be executed as an e-BLUT — through e-stamp or another digital mechanism — and signed using a Digital Signature Certificate.
What Changed After Instruction No. 123?
The earlier requirement to execute the BLUT on physical non-judicial stamp paper, notarised by a Notary Public, was done away with. Instruction No. 123 superseded the older Instruction No. 02 of 24 March 2006 that had set out that physical process.
How Is BLUT Submitted Through SEZ Online?
A unit files its BLUT through the legal undertaking module on the SEZ Online portal, using the New LUT request route, along with Form-H and its supporting documentation.
What Is a ‘New LUT’ Request?
It is the specific filing type within SEZ Online’s legal undertaking module that a unit uses to submit a fresh Bond-cum-Legal Undertaking for review and approval.
Can the BLUT Bond Amount Be Updated?
The bond value is tied to a calculation sheet submitted with the filing. This article does not state a universal figure or percentage — confirm the applicable calculation methodology and any update process directly through current IFSCA guidance.
Is BLUT the Same As the LOA?
No. The LOA, issued under Rule 19, authorises the unit’s specific SEZ operations. The BLUT is a separate compliance bond and undertaking that follows the LOA.
Is BLUT the Same as a Lease Deed?
No. The Lease Deed is the registered document confirming the unit’s premises, due within six months of the LOA date. The BLUT is a distinct compliance instrument covering the unit’s broader SEZ undertakings.
Does BLUT Give an Entity IFSCA Regulatory Authorisation?
No. The BLUT is an SEZ compliance document. Sector-specific IFSCA authorisation — for banking, fund management, insurance, or another regulated activity — is a separate requirement that sits alongside it.
What Documents Are Generally Required?
Form-H itself, the unit’s SEZ and entity identification details, the bond-value calculation sheet, and supporting documentation confirming the figures declared. Exact requirements should be confirmed against current IFSCA and SEZ Online guidance.
What Happens After BLUT Approval?
The unit typically moves toward its registered Lease Deed, its Eligibility Certificate, any remaining activity-specific registrations, and eventual commencement of operations, which it then intimates to the Administrator (IFSCA).
Does Buying Property in GIFT City Require a BLUT?
No. The BLUT requirement applies to businesses operating as SEZ/IFSC units. An individual or investor purchasing residential or commercial property in GIFT City, without operating as an SEZ unit, has no BLUT obligation.
Sources & References
This article reflects the current SEZ compliance framework for GIFT IFSC units at the time of writing, including the electronic BLUT execution process introduced by Instruction No. 123 dated 23 February 2026. Procedures, forms, and approval processes are set by the Ministry of Commerce, the SEZ authority, and IFSCA, and are periodically updated — always verify the current position before relying on any step described here.
IFSCA — SEZ Compliance FAQs Booklet, Version 2.0 (Office of the Administrator, IFSCA), 20 August 2026
https://www.ifsca.gov.in/SezMeeting/Index
IFSCA — Public Notice No. 06/2026-27, Process of approval of BLUT for IFSC Units, 12 August 2026
https://www.ifsca.gov.in/SezMeeting/Index
Ministry of Commerce and Industry — Instruction No. 123 dated 23.02.2026, Execution of BLUT by SEZ Developers/Units
https://sezindia.gov.in/instructions
Ministry of Commerce and Industry — Special Economic Zones Rules, 2006 and amendments
https://sezindia.gov.in/sez-rules-and-amendments
SEZ Rules — Form-H, Bond-cum-Legal Undertaking for SEZ Unit
https://www.sezindia.gov.in/sites/default/files/sez_rules_amendments/23SEZRulesincorporatingallamendments.pdf
IFSCA — Workflow for Setting up a Unit in GIFT IFSC, June 2026
https://ifsca.gov.in
GIFT City official portal — master plan, zones and setup process
https://giftgujarat.in
Gujarat Real Estate Regulatory Authority (RERA) — project registration verification
https://gujrera.gujarat.gov.in
This article is general information for awareness purposes only and is not legal, tax, or regulatory advice. Businesses evaluating their GIFT City BLUT requirement should confirm the current process, forms, and approval framework with qualified legal and compliance professionals, or directly with IFSCA, before proceeding.
