Freight forwarders should immediately review their contractual arrangements and insurance coverage following the implementation of the International Air Transport Association’s (IATA) revised Direct Air Waybill (DAWB)framework, according to digital cargo insurance provider Breeze.
The company says the new framework, which took effect on 1 July 2026, could significantly alter the allocation of legal responsibilities between airlines, shippers and freight forwarders, creating uncertainty around liability and raising questions over whether existing insurance policies remain fit for purpose. The revised DAWB framework has also prompted wider industry concern, with organisations including FIATA and the Airforwarders Association (AfA)calling for greater clarity on liability allocation and implementation across airlines.
Potential shift in contractual liability
According to Breeze, the revised contractual framework could result in freight forwarders assuming responsibilities that have traditionally rested with shippers or air carriers.
Matthew Phillips, Chief Commercial Officer at Breeze, described the changes as a significant development for the freight forwarding sector.
“Without a doubt, this represents a significant reallocation of risk.
Liability is generally expected to follow control, and the revised framework raises legitimate questions where a freight forwarder could potentially become responsible for matters traditionally associated with the shipper or carrier.”
Phillips added that uncertainty may be compounded if airlines adopt the revised framework differently.
“The uncertainty is increased if implementation differs between airlines, meaning forwarders may need to understand the contractual position on a carrier-by-carrier basis.”
His comments echo broader industry concerns that inconsistent implementation could create varying contractual obligations depending on the airline involved.
Insurance policies may require reassessment
Breeze notes that traditional freight forwarder liability insurance has historically been designed to protect against risks arising from the forwarder’s own activities, including operational errors, omissions and negligence in arranging transportation.
However, if the revised DAWB framework shifts additional contractual obligations onto freight forwarders, insurers may need to reassess how these risks are underwritten.
The company believes this could eventually influence policy wording, underwriting criteria and insurance premiums as the market develops a clearer understanding of the practical legal implications of the revised arrangements.
Rather than waiting for the insurance market to adapt, Breeze is encouraging freight forwarders to take proactive steps to minimise exposure.
Cargo insurance seen as immediate safeguard
Phillips said one of the most practical measures available is ensuring that cargo itself is adequately insured.
“The most practical step forwarders can take today is to confirm whether the shipper has comprehensive all risks cargo insurance and, where appropriate, offer cover on a shipment-by-shipment basis.”
He said this approach provides immediate protection for cargo owners while reducing uninsured exposure throughout the supply chain during the industry’s transition to the revised framework.
By encouraging wider adoption of comprehensive cargo insurance, Breeze believes freight forwarders can better protect both their customers and their own businesses against potential contractual uncertainties.
Industry seeks greater legal clarity
The revised IATA Direct Air Waybill framework has generated considerable debate across the global air cargo industry since its implementation on 1 July.
The framework is intended to rebalance contractual responsibilities between airlines and freight forwarders, but industry associations have questioned whether the changes have been introduced without sufficient legal, operational and insurance assessment.
Earlier this year, FIATA formally requested a review of the amendments under the IATA-FIATA Consultative Council mechanism, citing concerns over liability allocation, legal certainty and market stability. More recently, the organisation urged airlines worldwide to clarify how they intend to implement the revised framework after reporting that implementation could vary between carriers.
Similarly, the Airforwarders Association (AfA) has advised freight forwarders to obtain written confirmation from individual airlines regarding the contractual arrangements that will apply before accepting shipments under the new framework.
Preparing for an evolving regulatory landscape
As airlines, freight forwarders, insurers and shippers adapt to the revised DAWB framework, industry experts expect closer collaboration between all parties to ensure contractual responsibilities are clearly understood.
For freight forwarders, reviewing contractual terms, engaging with insurance providers and confirming adequate cargo insurance coverage may become increasingly important steps in managing operational and legal risk as implementation continues across the global air cargo industry.
