- FIATA has formally requested a review of proposed changes to the Direct Air Waybill (DAWB) framework adopted by International Air Transport Association, arguing that the measures were introduced with insufficient consultation on their legal, operational and insurance implications ahead of a planned 1 July 2026 implementation date.
- Industry stakeholders, including freight forwarders, airlines, insurers and shippers, have raised concerns that the new DAWB framework could create legal uncertainty by shifting liability and indemnity exposure onto freight forwarders even where they do not exercise operational control over cargo data, compliance or transport processes.
- FIATA is seeking a structured industry-wide reassessment through the IATA-FIATA Consultative Council review mechanism, warning that the proposals could disrupt claims handling, contractual relationships and risk allocation across the global air cargo supply chain at a time of wider geopolitical and operational instability.
FIATA has formally called for a comprehensive review of controversial changes to the Direct Air Waybill (DAWB) framework adopted by International Air Transport Association (IATA), warning that the proposed measures could create widespread legal, operational and insurance-related uncertainty across the global air cargo industry if implemented without broader stakeholder alignment.
The move marks one of the most significant recent interventions by the global freight forwarding community in response to regulatory and contractual changes affecting international airfreight operations. FIATA has invoked the review mechanism available under the IATA-FIATA Consultative Council (IFCC), seeking a structured reassessment of the proposals before their scheduled implementation date of July 1, 2026.
At the heart of the dispute is growing concern among freight forwarders, insurers, shippers and legal experts that the revised DAWB framework could fundamentally alter the allocation of contractual liability within the air cargo supply chain — potentially transferring additional responsibility and indemnity exposure onto freight forwarders even in situations where they do not exercise operational control over cargo data, compliance procedures or transportation processes.
Industry Pushback Intensifies Over Liability Exposure
FIATA said the request for review follows extensive consultations conducted globally with stakeholders from across the logistics and aviation sectors, including freight forwarders, airlines, insurers, legal specialists and cargo owners.
According to the organisation, a consistent theme emerged throughout these discussions: liability should remain proportionate to operational control and aligned with the party actually performing the relevant transport or compliance function within the supply chain.
Many stakeholders reportedly expressed concern that the proposed DAWB reforms risk creating a disconnect between operational responsibility and legal liability, potentially exposing freight forwarders to increased claims and indemnity obligations despite acting solely as intermediaries or agents on behalf of shippers.
Industry representatives argued that freight forwarders frequently do not control the underlying cargo information, customs compliance procedures or security declarations associated with shipments, yet under the proposed structure may still face expanded liability exposure.
Several stakeholders also warned that such changes could create uncertainty regarding contractual accountability throughout the cargo chain, potentially affecting claims management, insurance coverage and long-established commercial relationships between airlines, forwarders and shippers.
Concerns Raised Over Accelerated Consultation Process
A major source of frustration within the forwarding and insurance community relates to the pace at which the proposals progressed through the industry consultation process.
FIATA stated that IATA communicated the proposed reforms to the freight forwarding sector only in January 2026, shortly before Regional Joint Council and IFCC consultations took place.
According to the association, this left insufficient time for stakeholders to conduct detailed legal analysis, operational evaluations and insurance assessments of changes carrying potentially far-reaching implications for international air cargo operations.
Industry observers note that liability frameworks in airfreight are highly complex and interconnected, involving multiple jurisdictions, contractual structures and internationally recognised legal conventions.
As a result, changes affecting risk allocation and contractual obligations typically require lengthy technical evaluation and cross-sector consultation before implementation.
FIATA argued that proposals of this magnitude should not be introduced through an accelerated process without comprehensive industry-wide impact assessment and consensus-building among affected stakeholders.
Insurance Sector Flags Potential Claims and Coverage Challenges
The insurance community has emerged as one of the most vocal groups expressing concern over the proposed framework.
FIATA said insurers participating in industry consultations highlighted uncertainty regarding the insurability of risks where liability may be imposed on parties lacking direct operational control.
According to stakeholders involved in the discussions, this uncertainty could complicate underwriting practices, disrupt established claims-handling procedures and reduce predictability in determining legal responsibility following cargo incidents or compliance disputes.
Insurers reportedly warned that disconnecting liability exposure from operational control may create ambiguity regarding which party ultimately bears responsibility in the event of cargo loss, regulatory breaches or shipment irregularities.
Industry analysts believe such uncertainty could have broader consequences for cargo insurance markets, particularly as insurers increasingly focus on clearly defined liability structures and risk accountability amid growing geopolitical and operational volatility.
Broader Supply Chain Stability at Stake
FIATA’s intervention comes at a time when the global air cargo sector is already facing significant external pressures, including geopolitical instability, supply chain disruption, evolving customs regulations, trade tensions and rising operational costs.
Against this backdrop, stakeholders have argued that preserving legal clarity and contractual predictability across international logistics networks is more critical than ever.
FIATA warned that introducing structural changes to liability frameworks without sufficient legal and operational clarity risks increasing disputes over contractual responsibility, weakening established recourse mechanisms and disrupting the smooth functioning of global cargo movements.
The organisation also stressed the importance of maintaining consistency with internationally recognised legal instruments such as the Montreal Convention, which forms the cornerstone of liability allocation in international air transport.
Industry experts note that the Montreal Convention has historically provided a globally accepted framework supporting legal certainty, uniformity and predictability in international cargo claims and carrier liability matters.
FIATA Calls for Balanced and Inclusive Industry Dialogue
While critical of the current process, FIATA emphasised that it recognises the underlying concerns raised by airlines regarding compliance obligations, due diligence requirements and risk visibility within increasingly complex global supply chains.
However, the association argued that any solution must be developed collaboratively and ensure that liability exposure remains appropriately aligned with operational responsibility and insurable risk.
FIATA said the IFCC review mechanism offers an opportunity for a broader, more structured reassessment involving all affected stakeholders, including airlines, freight forwarders, insurers and shippers.
The organisation believes that such a review process would allow the industry to explore alternative approaches capable of addressing airline concerns without creating unintended legal or commercial imbalances across the supply chain.
FIATA reiterated its commitment to constructive engagement with IATA and industry stakeholders in pursuit of operationally workable and legally coherent solutions that reinforce resilience, clarity and predictability throughout the global air cargo ecosystem.
Potential Long-Term Implications for Global Air Cargo
Industry observers say the outcome of the review request could carry significant implications for the future structure of contractual liability and digital cargo documentation within the international airfreight market.
As airlines, freight forwarders and regulators continue modernising cargo processes through digitisation and evolving compliance standards, the allocation of legal responsibility within increasingly interconnected supply chains is becoming a central issue for the industry.
The debate surrounding the DAWB reforms highlights the growing tension between operational efficiency, compliance oversight and legal accountability in global cargo transportation.
For now, stakeholders across the aviation logistics sector will be closely watching whether IATA agrees to reopen discussions and whether the proposed implementation timeline will ultimately be reconsidered.







