Breeze joins FIATA and the Airforwarders Association in raising concerns over legal liability and risk allocation under the revised DAWB framework
The implementation of the International Air Transport Association’s (IATA) revised Direct Air Waybill (DAWB)framework is prompting fresh calls for freight forwarders to reassess their contractual obligations and insurance coverage, as industry stakeholders warn of potentially significant changes in the allocation of legal responsibilities across the air cargo supply chain.
Digital cargo insurance specialist Breeze has become the latest organisation to express concerns over the revised framework, which came into effect on 1 July 2026. The company believes the changes could alter the balance of legal responsibility between airlines, shippers and freight forwarders, creating uncertainty over liability and exposing forwarders to risks that may not be covered under existing insurance policies.
The warning echoes concerns previously raised by the US Airforwarders Association (AfA) and the International Federation of Freight Forwarders Associations (FIATA). While the AfA advised freight forwarders to review contracts with every airline and verify their insurance arrangements, FIATA had earlier called for a postponement of the revised DAWB framework to allow more time for industry consultation and implementation.
A Significant Shift in Risk Allocation
According to Matthew Phillips, Chief Commercial Officer at Breeze, the revised framework could fundamentally change the way legal responsibility is assigned within the air cargo chain.
“Without a doubt, this represents a significant reallocation of risk,” Phillips said.
“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.”
He added that the situation could become even more complex if airlines implement the revised framework differently, requiring freight forwarders to assess contractual obligations on a carrier-by-carrier basis.
“The uncertainty is increased if implementation differs between airlines, meaning forwarders may need to understand the contractual position on an individual airline basis,” he noted.
Insurance Policies May Need to Evolve
Traditionally, freight forwarders’ liability insurance has been designed to cover risks directly under their control, including operational errors, omissions and negligence when arranging transportation.
However, Breeze cautions that if freight forwarders begin assuming responsibilities previously borne by shippers under the revised contractual structure, insurers may need to reassess underwriting criteria, policy conditions and premium structures as the practical implications of the new framework become clearer.
Rather than waiting for insurance products to adapt, Breeze is encouraging forwarders to take immediate steps to minimise potential exposure.
“The most practical step forwarders can take today is to confirm whether the shipper has comprehensive all-risk cargo insurance and, where appropriate, offer additional cover on a shipment-by-shipment basis,” Phillips explained.
“That provides immediate protection for the cargo owner while helping reduce uninsured exposure across the supply chain as the industry adapts to the revised framework.”
Industry Seeks Greater Clarity
The revised DAWB framework is intended to modernise contractual relationships between airlines and freight forwarders by redefining certain responsibilities within the shipment process. However, the changes have sparked widespread discussion throughout the air cargo industry over their legal, operational and insurance implications.
Industry bodies have stressed that successful implementation will depend on consistent application across airlines and clear communication between carriers, freight forwarders, insurers and shippers.
As the new framework begins to take effect globally, freight forwarders are expected to undertake comprehensive reviews of airline agreements, customer contracts and insurance programmes to ensure they fully understand their obligations under the revised operating environment.
The debate surrounding the new Direct Air Waybill framework also highlights the increasing importance of legal certainty and risk management in an industry where contractual liability, cargo protection and regulatory compliance remain critical to maintaining resilient and efficient global supply chains.
