Airfreight Logistics Issues – IATA’S Revised Direct Air Waybill

Airway bills are central to the movement of air cargoes around the globe. They record the contract of carriage from the place of lading to the place of unloading, as well as governing the legal obligations between the various parties who are involved.

On 1 July 2026, the International Air Transport Association (IATA) have introduced amendments to its Direct Air Waybill (DAWB) which could have a significant impact on these legal obligations for airlines, freight forwarders, and shippers.

The Role of a Direct Air Waybill (DAWB) in Practise

A DAWB is a single transport contract issued directly by an airline to the actual shipper of shipment goods, even where a freight forwarder has arranged the shipment directly with the carrier. The freight forwarder’s name does not appear on the bill itself either as a carrier or shipper on the record. The practise of naming the shipper on the DAWB is often required by the shipper in response to its commercial relations or finance obligations with third parties, or because of documentary requirements. It is particularly relevant when dealing with high-value, time sensitive shipments, where there usually needs to be a direct contractual relationship on paper between the carrier and the shipper. Although the current system works well, there was broad recognition that the sector needed greater accountability and transparency. The airlines also felt they were facing greater exposure to shipments which were either dangerous, such as lithium batteries, or complex e-commerce shipments which can be challenging.

Why Has IATA Revised the DAWB Framework?

IATA felt there was a need to clarify the legal relationships, whilst openly admitting that the identity of the party on an Airway Bills does not of itself determine who has responsibility for the risks associated with a shipment. Their view was that this was underpinned by international law that distinguishes between a party that provides cargo related particulars and parties that receive and then transmit particulars about shipments.  They also highlighted that most shipments are presented in a sealed condition and the true condition and other information about the shipment tends to lie with the shipper. A more robust system was required to align responsibility with the activities being performed, with an emphasis on the principal “Liability should follow role, control and fault.”

The Changes

Where a freight forwarder tenders cargo to an airline using a DAWB structure with a third-party shipper shown in the “Shipper” box, the carrier and the forwarder should now enter into a separate bilateral contract which includes risks and indemnities. If no bespoke bilateral agreement is entered into, then the default position is that the forwarder is deemed to accept the same terms and conditions in the DAWB as if they were the actual shipper.

In practical terms, that means the forwarder could find themselves in the front line on issues such as cargo information, customs, freight charges, dangerous goods, compliance, and general cargo security.

Current situation

There has been a strong reaction from the freight forwarding community to the changes IATA has implemented and an attempt to delay its implementation, but the new rules have come into operation on 1 July. It will be for individual airlines to decide whether they will implement the proposed changes.

Practical Steps across the board

Airlines need to assess key forwarder accounts if they choose to take up the new amendments proposed by IATA.

Freight forwarders must ensure they have bilateral agreements in place with carriers dealing with these risks, or the default position will automatically apply.

Forwarders and Shippers must ensure their contractual arrangements are in place to cover these changes. Customs irregularities, export breaches, and dangerous goods are the most common risks which need to be addressed.

Individual Steps

What Do the Changes Mean for Airlines and Forwarders?

The new framework potentially provides a clear contractual route to pursue a freight forwarder rather than the shipper with whom they may have no commercial relationship. A review of bilateral agreements with key forwarders accounts should be looked at with some urgency.  It is unclear whether the new rules were intended to have retroactive effect.

What Do the Changes Mean for Freight Forwarders?

Forwarders should discuss with individual airlines whether they have decided to implement IATA’s new framework and, if so, to determine the bilateral terms.

At the same time, there will need to be a review of standard operating terms with shippers to reflect the much greater risk forwarders might be exposed to on a few fronts from customs to freight charges. Indemnity arrangements as well as insurance will need to be reviewed.

For higher risk cargoes, alternative and higher-level indemnities and insurance might be required.

What Do the Changes Mean for Shippers?

Freight forwarders will look to strengthen their processes when accepting information about shipments as well as enhanced indemnities. Shippers may need to review their own arrangements with manufacturers and third parties.

Cargo insurance will form a critical component in the new structure, and policies should be checked.

Questions should be posed to a forwarder to learn about their arrangements with the air carrier and whether a bilateral agreement is in place.