The air waybill is the least glamorous document in the supply chain and the most important. It is the contract of carriage, the receipt for your goods, and the paper trail that decides who pays when something goes wrong. This year, IATA quietly changed how that contract is read, and the industry is still arguing about where the risk now sits. As of this month, the people asking the sharpest questions are no longer only the forwarders. They are the shippers.
What actually changed
At the centre of the row is a revamp of the direct air waybill (DAWB) framework, agreed through IATA’s Cargo Agency Conference (reported as Resolution 801c) and pushed out to the industry on a tight timetable. The proposed changes were communicated in January 2026, adopted in March, and carried an implementation deadline of 1 July 2026.
The mechanics are technical, but the effect is not. Under the revised framework, a freight forwarder acting as the shipper’s agent can be treated as the contractual shipper on the air waybill, even when the actual shipper is named on the document. In plain terms, the party that signs the goods onto the aircraft can inherit obligations that used to belong to the party that owned, packed and declared them.
IATA’s rationale is a familiar one for carriers. Airlines have long complained that they end up in a contract of carriage with a party they cannot see or vet. Carlos Tornero, IATA’s director of legal services, framed the problem as airlines having “essentially entered into a contract with an entity they do not know,” with no direct line of sight on compliance.
Why the risk moved, rather than disappeared
The hard edge of the change is liability for the things that go wrong most expensively: misdeclared or concealed dangerous goods, and packaging that fails in flight. Those are precisely the exposures a forwarder has the least control over, because the declaration, the classification and the packing usually happen upstream, at the shipper’s dock.
Forwarder bodies have been blunt about the mismatch. Brandon Fried, executive director of the Airforwarders Association, put the core objection this way:
- The named-party problem: “The core problem is that a forwarder can end up treated as the contractual shipper, even when the real shipper is named right there on the waybill.”
- The control problem: “Freight forwarders should not be expected to assume liability for cargo they neither own, pack, nor control.”
- The insurance problem: “Forwarder liability insurance is designed around the services freight forwarders actually perform, not around assuming shipper obligations.”
FIATA, the global forwarders’ federation, has argued the same principle from the top. Director general Stéphane Graber warned that “freight forwarders cannot reasonably be expected to assume significant new contractual obligations or liabilities outside their function without legal certainty or a proper opportunity to assess the resulting operational and insurance implications,” and the federation has called for responsibility to stay “aligned with the party exercising actual operational control and performing the relevant functions.” One forwarder, quoted anonymously, called the shift “a game-changer for the industry beyond comprehension.”
Now the shippers have noticed
For most of 2026 this looked like a fight between airlines and forwarders. That changed this month. The Global Shippers Forum has now weighed in, and its director James Hookham made clear that the cargo owners, the people whose goods are actually moving, are only now realising they are part of the story.
Hookham said he “was surprised by the number of shippers that are affected by this,” and warned that re-routing liability through the forwarder “creates uncertainty, possibly risk; certainly for the forwarder community.” His conclusion was not reassuring for anyone hoping the matter settles quietly: “Unfortunately, I think this is going to end up with the lawyers.”
Two practical problems compound the legal one. The first is that implementation has been patchy, not every airline applied the new framework on 1 July, so the same shipment can be treated differently depending on the carrier. The second is that the uncertainty itself has a cost, long before any court rules on who is right.
What it means for your freight
A contract you do not read is still a contract you are bound by. For shippers and forwarders alike, this change raises the price of sloppy paperwork and rewards the opposite.
- Know who is named, and as what. Whether a party appears as shipper, agent or contractual shipper on the air waybill now carries real consequences. It is worth confirming on your lanes rather than assuming last year’s answer still holds.
- Get the declaration right at source. Classification, dangerous-goods declarations and packing information all originate upstream. Clean, accurate documentation at booking is the single biggest lever on where liability lands, and on whether your cargo makes the flight at all.
- Check the insurance fits the risk. Liability cover built around traditional forwarding functions may not stretch to assumed shipper obligations. The gap is worth a conversation with your broker and insurer now, not after a claim.
- Expect carrier-by-carrier variation. Until implementation settles, treat the framework as a live variable in carrier selection, not a solved one.
This is where neutrality earns its keep. A broker tied to no single carrier can read how each airline is actually applying the framework, make sure your documentation is correct and consistent before the booking is made, and keep the paperwork clean across every lane, so the question of who is liable never has to be answered the hard way.
The bottom line
IATA’s direct air waybill overhaul has not removed risk from the system; it has moved it, onto intermediaries whose role has not changed. The dispute is unresolved, implementation is uneven, and the shipper community has only just arrived at the table. Whatever the lawyers eventually decide, the defensible position today is the same one it always was in air cargo: accurate declarations, correct documentation, and no assumptions about who is carrying the risk.
At ACC, we treat your air waybill as a contract, not a formality. If you want a clear read on where liability sits on your lanes, and documentation that holds up whatever a carrier’s framework says, talk to us before your next booking, not after.
Sources: The Loadstar (1 Oct 2026) · The Loadstar, “‘Bizarre’ direct air waybill revamp a ‘game-changer’ for forwarders” (1 Jul 2026) · Air Cargo News, “Forwarders hit out at IATA changes to Direct AWB framework” (May 2026) · Air Cargo Week / AJOT, Airforwarders Association risk warning (3 Jul 2026) · FIATA statements via Air Cargo News (Jun 2026)
