IATA Changes to Direct Air Waybill Liability - Member Feedback Requested

Tuesday, April 28, 2026

Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA), as Australia's representative to the Global Shipper's Forum (GSF), are seeking member feedback on proposed changes by the International Air Transport Association (IATA) to recommended airline terms and conditions relating to the use of Direct Air Waybills (DAWBs).

The changes, understood to take effect from Wednesday 1 July 2026, may significantly alter the liability position of freight forwarders and shippers where a DAWB is used.

What is changing?

In a standard air cargo movement, a freight forwarder may purchase cargo space from an airline and act as a consolidator for client shippers. In those circumstances, the freight forwarder is generally shown as the Shipper on the Air Waybill and assumes the associated shipper responsibilities and liabilities.

However, in some circumstances, a shipper may request, or may be required by local law, to appear as the named Shipper on the Air Waybill and effectively contract directly with the airline. This is commonly referred to as a Direct Air Waybill.

Under this model, the freight forwarder may still tender the shipment to the airline, but does so as the shipper's agent rather than as the contractual carrier.

FTA / APSA understand that IATA is now revising the recommended terms and conditions for airlines so that, where a DAWB is used, the freight forwarder may be required to agree indemnities with the carrier or otherwise be treated as assuming the same responsibilities and liabilities as if it were the shipper.

In practical terms, this may mean the airline continues to hold the freight forwarder liable for costs, claims, penalties, damage or other consequences arising from the shipment, even where the Air Waybill names the shipper as the contracting party.

Dangerous Goods liability

Of particular concern are proposed changes that may also transfer responsibility and liability for Dangerous Goods shipments to the freight forwarder, regardless of the role the forwarder plays in the shipment.

This raises obvious concerns for freight forwarders acting only as agents, particularly where operational control, documentation, cargo declarations and packaging information sit with the shipper or other parties in the supply chain.

Potential impacts for shippers and forwarders

The Global Shippers Forum (GSF) has been notified of these developments by FIATA, which has raised concerns about the implications for forwarder liability when acting as an agent for air cargo shippers.

The proposed changes may also have broader implications for shippers who regularly use DAWBs, including:

whether the named direct shipper can bring claims directly against the carrier;
whether airlines will only engage with the freight forwarder as the responsible party under the amended terms;
additional complexity, cost and delay in claims handling between shippers, forwarders and carriers;
increased risk and insurance costs for freight forwarders;
reduced commercial value and practical usefulness of DAWBs; and
uncertainty as to whether shippers can continue to contract and deal directly with their chosen airline in the way originally intended.

Call for member feedback

FTA/APSA are seeking feedback from members on the operational implications of the proposed changes, with any objections to be considered via an industry response to IATA at the Cargo Agency Conference in June 2026.

FTA / APSA are seeking early feedback from members, particularly those who use, issue, facilitate or rely on Direct Air Waybills.

Members are invited to provide comments on:

how often DAWBs are used in your air cargo operations;
why DAWBs are used — for example, shipper preference, airline requirement, customer requirement or local legal requirement;
whether the proposed liability shift would affect your willingness to use DAWBs;
whether the changes would increase insurance, compliance or operational costs;
whether the proposed Dangerous Goods liability position creates specific concerns;
whether the changes may affect claims handling or the ability of shippers to deal directly with airlines; and
any examples of DAWB use cases that would be disrupted or made commercially unviable by the proposed changes.

Next steps

FTA / APSA will collate member feedback and provide input through appropriate international channels.

Please send feedback to tjensen@FTAlliance.com.au by Friday 10 May 2026 so that member views can be considered accordingly.