Freight Forwarding Community Warns Proposed DAWB Changes Could Reshape Risk Allocation Across Global Air Cargo Supply Chains
A significant policy debate is unfolding within the global air cargo industry as the International Federation of Freight Forwarders Associations (FIATA) calls for a formal review of proposed changes to the Direct Air Waybill (DAWB) framework adopted by the International Air Transport Association (IATA). Freight forwarders argue that the amendments could fundamentally alter established liability principles, expose intermediaries to greater legal and financial risks, and create uncertainty around responsibility for compliance-sensitive cargo movements, including dangerous goods shipments.
The global air freight industry is facing renewed scrutiny over liability allocation and supply chain accountability following FIATA’s request for a formal review of IATA’s proposed revisions to the Direct Air Waybill (DAWB) framework.
The proposed changes, approved by IATA earlier this year and scheduled to take effect on July 1, 2026, have triggered widespread concern among freight forwarders, insurers and legal specialists who fear the new framework could disrupt long-established principles governing responsibility within international air cargo transportation.
At the heart of the debate is the role of freight forwarders acting as agents on behalf of shippers. Industry stakeholders argue that the revised framework may significantly increase liability exposure for forwarders, even in circumstances where they neither own the cargo nor exercise operational control over shipment preparation, packaging, documentation or regulatory compliance.
Industry Raises Concerns Over Liability Alignment
FIATA said extensive consultations conducted with freight forwarders, airlines, insurance providers, legal experts and cargo owners have identified a number of areas requiring further examination before implementation.
According to the organisation, the proposed framework risks creating a disconnect between legal liability, operational control and insurable risk—three pillars that traditionally underpin international freight forwarding and transportation contracts.
Particular concern has been expressed regarding dangerous goods shipments, where responsibility for cargo declarations, packaging standards and compliance requirements often resides with shippers and specialised service providers rather than forwarding agents.
Industry groups have warned that if liability shifts toward freight forwarders without corresponding operational authority, businesses could face increased legal exposure and insurance complexities while having limited ability to mitigate the associated risks.
FIATA maintains that responsibility should remain linked to the party performing and controlling the relevant function within the supply chain, a principle widely recognised across international transport conventions and commercial practice.
Formal Review Requested Through Industry Governance Framework
In response, FIATA has invoked the review provisions available through the IATA-FIATA Consultative Council (IFCC), seeking a comprehensive reassessment of the proposed amendments before they are implemented globally.
The organisation argues that reforms with far-reaching legal and commercial implications require broader consultation and a more detailed evaluation of their operational consequences.
Stakeholders have also questioned the pace of the implementation process, noting that the proposals were communicated in January, adopted in March and are due to enter into force in July—a timeline many consider insufficient for comprehensive legal, insurance and operational analysis.
The request comes at a time when the air cargo sector continues to navigate geopolitical instability, shifting trade patterns, capacity disruptions and rising operating costs, making regulatory certainty and contractual clarity increasingly important for supply chain resilience.
Airlines Push for Greater Transparency and Accountability
While freight forwarders have called for additional review, IATA has defended the reforms as a necessary response to evolving compliance and risk management challenges facing airlines.
According to IATA, the current DAWB structure can leave carriers exposed because freight forwarders frequently tender cargo as agents of shippers, while airlines may have limited visibility into the underlying cargo owner, compliance history or commercial relationship.
The association argues that airlines are increasingly required to meet stringent obligations related to sanctions compliance, anti-money laundering controls, security screening and dangerous goods oversight. As a result, carriers are seeking stronger accountability mechanisms within the contractual framework governing cargo acceptance.
IATA has also highlighted the challenges associated with pursuing legal recourse against cargo owners in the event of incidents involving misdeclared or non-compliant shipments, particularly when the shipper is located in another jurisdiction and has no direct contractual relationship with the airline.
Potential Impact on Global Air Cargo Operations
The outcome of the review process could have significant implications for the structure of commercial relationships throughout the air cargo ecosystem.
Should the proposed framework proceed without modification, freight forwarders may need to reassess contractual arrangements, compliance procedures, insurance coverage and risk management strategies. Airlines, meanwhile, are likely to continue advocating for enhanced transparency and accountability as regulatory requirements become increasingly stringent.
Legal experts note that any adjustment to liability structures within international air cargo must be carefully balanced to ensure consistency with established legal conventions while preserving operational efficiency and commercial certainty.
Industry Awaits Outcome
The discussion surrounding the DAWB framework reflects a broader evolution within the air cargo industry as stakeholders seek to strengthen supply chain security, improve compliance standards and clarify accountability in an increasingly complex trading environment.
While both airlines and freight forwarders acknowledge the need for greater transparency and risk management, the current debate highlights differing views on how responsibility should be allocated and where legal liability should ultimately reside.
As implementation deadlines approach, industry attention will now turn to the review process and whether a revised framework can be developed that balances airline risk concerns with the operational realities faced by freight forwarders worldwide.
