Aviation Transport Security Act 2004 (Cth) — consignor/forwarder obligations

Aviation Transport Security Act 2004 + Regulations 2005 — freight forwarder consignor obligations (non-RACA scope)

Requirements: 8
Last reviewed: 16/04/2026
Next review: 16/04/2027
Source: Current compilations at 2026-04-16

Reconciliation notes

Curated build covering consignor/freight forwarder obligations under the Aviation Transport Security Act 2004 for a freight forwarder that: (a) arranges international air freight, (b) does NOT hold RACA registration, (c) engages registered RACAs to arrange air transport, (d) does not hold ASICs — staff escorted by agents where required. Westlink sits outside the clearance chain — the RACA assumes responsibility for cargo examination and security declaration issuance. Obligations captured here are consignor/shipper duties that apply regardless of RACA engagement. Known Consignor scheme: Westlink likely does not qualify for third-party cargo (requires manufacture/own/control at lowest deconsolidation level); voluntary and not required. CASR Part 92 dangerous goods shipper obligations are a parallel regime — captured as a watchpoint row since Westlink does not currently consign DG (consistent with DG deferral noted in compliance library README). Total requirements: 8. Applicable: 7. Reference-only: 1. Sources: ATSA ss.44A-44C (AustLII verified), Home Affairs draft regulation (Regs 4.41E, 4.41H verified), Known Consignor Information Booklet.

Requirements

Showing 8 of 8 requirements

ID	Clause	Requirement	Applicability	Coverage	Evidence	Gap
AVSEC-DEC-01	Aviation Transport Security Regulations 2005 Reg 4.41E (as inserted by Amendment (Cargo) Regulation 2016)	A person commits a strict liability offence if they purport to issue a security declaration for air cargo and are not a known consignor or regulated air cargo agent (RACA). All security declarations must be issued by the receiving RACA or an approved known consignor. Penalty: 50 penalty units (~$16,500).	Applicable	Full	OPS-PRO-001 §§9 Air-Cargo Security — OPS-PRO-001 §9 Air-Cargo Security establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — truthful dealings with regulators — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
AVSEC-DEC-02	Aviation Transport Security Regulations 2005 Reg 4.41H (as inserted by Amendment (Cargo) Regulation 2016)	It is an offence to load cargo onto a prescribed aircraft without a valid security declaration. An entity that causes or directs cargo to be loaded without a valid declaration is liable. Penalty: 50-100 penalty units depending on entity classification.	Applicable	Full	OPS-PRO-001 §§9 Air-Cargo Security — OPS-PRO-001 §9 Air-Cargo Security establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — truthful dealings with regulators — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
AVSEC-INFO-01	Aviation Transport Security Act 2004 s.10 (unlawful interference with aviation)	Communicating false or misleading information that could endanger the safety of an aircraft or persons constitutes unlawful interference with aviation — a criminal offence under the Act. Providing a false cargo description (e.g., misdeclaring contents, omitting hazardous characteristics) to a RACA that then clears cargo based on that description creates direct exposure. Applies to all persons, not just aviation industry participants.	Applicable	Full	OPS-PRO-001 §§9 Air-Cargo Security — OPS-PRO-001 §9 — air-cargo description accuracy control; ATSR 4.41D/F/G/H declaration plus the Criminal Code s.137.1/137.2 false-statement training control. GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — truthful dealings with regulators — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
AVSEC-TRN-01	Aviation Transport Security Act 2004 s.9 (aviation industry participant definition) + CISC guidance	Entities that make arrangements for the transport of cargo by aircraft are likely within the definition of 'aviation industry participant' under s.9 (needs verification against consolidated Act text). If so, employees and contractors involved in air freight operations must receive air cargo security awareness training covering: recognition of suspicious items, reporting obligations, and the security declaration framework. No prescribed curriculum for non-RACA entities; CISC publishes guidance.	Applicable	Full	OPS-PRO-001 §§9 Air-Cargo Security — OPS-PRO-001 §9 Air-Cargo Security establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Training and Awareness — GOV-POL-023 Training and Awareness — trade-control training — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
AVSEC-COC-01	Aviation Transport Security Act 2004 s.44B(3)	Cargo remains 'cleared' only if it has at all times been handled in accordance with regulations after receiving clearance. If Westlink takes custody of cargo after RACA clearance and before loading (e.g., in a consolidation depot), re-opening, consolidating, or transferring custody inconsistently with the RACA's security program voids the clearance, rendering cargo uncleared. Practical obligation: ensure clearance and handover to carrier occur through the RACA's controlled environment.	Reference only	Referenced-only	OPS-PRO-001 §§9 Air-Cargo Security — OPS-PRO-001 §9 Air-Cargo Security establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — air-cargo security and chain of custody — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.	Reference-only watchpoint (P1.2 relevance adjudication 2026-06-19, CF). The s.44B(3) chain-of-custody duty bites only if Westlink takes custody of cargo after RACA clearance and before loading; CF confirmed Westlink never takes such custody — clearance and handover occur through the RACA's controlled environment. Primary-source confirmed (ATSA s.44B(3) + s.9 'cleared' definition). Evidence links to OPS-PRO-001 §9 / GOV-POL-023 retained as precautionary watchpoint coverage (the documents still address air-cargo security); full traceability un-wiring deferred as disproportionate to a watchpoint reclassification. Re-open to Applicable if Westlink ever takes custody of cleared air cargo.
AVSEC-DD-01	Prudent control — no specific statutory obligation on consignors (ISO 9001 cl 8.4 supplier management applies)	While no specific section of the Act imposes a statutory due diligence obligation on a consignor to verify RACA registration, if Westlink tenders cargo to an entity purporting to be a RACA but not registered, the security declaration issued is invalid and cargo is uncleared. CISC publishes a public register of RACAs (verify availability). Prudent control: verify RACA registration at agent onboarding and annually; retain evidence.	Applicable	Partial	OPS-PRO-001 §§9 Air-Cargo Security — OPS-PRO-001 §9 Air-Cargo Security establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Policy Statement — GOV-POL-023 Policy Statement — air-cargo security and chain of custody — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.	Medium Control documented in OPS-PRO-001 §9 Air-Cargo Security (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (security-declaration records) accruing from the next operating cycle.
AVSEC-REC-01	Aviation Transport Security Regulations 2005 — 90-day retention obligation on RACA; prudent mirror control for consignor	Regulated businesses must retain records of security declarations for 90 days. The prescriptive obligation falls on the declaration issuer (the RACA), not the consignor. However, retaining copies of declarations as evidence of cargo clearance status is a prudent control for the consignor — provides evidence of compliance with Reg 4.41H (no loading without declaration) and supports audit/investigation defence.	Applicable	Full	OPS-PRO-001 §§9 Air-Cargo Security — OPS-PRO-001 §9 Air-Cargo Security establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle). GOV-POL-023 §§Records and Retention — GOV-POL-023 Records and Retention — five-year and air-cargo records — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
AVSEC-DG-WP-01	Civil Aviation Safety Regulations 1998 Part 92 + IATA Dangerous Goods Regulations	Dangerous goods shipper obligations for air freight sit under CASR Part 92 and IATA DGR, not the ATSA. The shipper (regardless of RACA status) must: classify, pack, mark, label, and document DG shipments correctly; provide a Shipper's Declaration for Dangerous Goods to the RACA/carrier; and not tender prohibited DG by air. Non-compliance penalties under CASR are separate from ATSA penalties.	Reference only	Referenced-only	—	Reference-only watchpoint — Westlink does not currently consign dangerous goods (confirmed operationally 2026-04-15). If air DG consignment commences, CASR Part 92 obligations activate as a direct shipper duty. Re-open this row alongside ADG/IMDG framework build (deferred per compliance library README DG watchpoint).

Source document

Aviation Transport Security Act 2004 + Regulations 2005 — freight forwarder consignor obligations (non-RACA scope)

8 normative shall-statements extracted from Aviation Transport Security Act 2004 (Cth) — consignor/forwarder obligations (source: Aviation Transport Security Act 2004 (Cth) + Aviation Transport Security Regulations 2005 + Aviation Transport Security Amendment (Cargo) Regulation 2016). The frontmatter requirements array is the source of truth — this body is rendered by scripts/render_compliance.py.

Coverage summary

Coverage	Count
✅ Full	5
🟡 Partial	1
🟠 Ref-only	2
🔴 Gap	0
— N/A	0

Gap severity distribution

Severity	Count
🔴 Critical	0
🟠 High	0
🟡 Medium	1
🟢 Low	0

Requirements

Clause Aviation Transport Security Act 2004 s

ID	Coverage	Evidence	Notes
AVSEC-INFO-01	✅ Full	[OPS-PRO-001 §‘§9 Air-Cargo Security’](/wms/OPS-PRO-001#s’§9 Air-Cargo Security’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
AVSEC-TRN-01	✅ Full	[OPS-PRO-001 §‘§9 Air-Cargo Security’](/wms/OPS-PRO-001#s’§9 Air-Cargo Security’) [GOV-POL-023 §‘§Training and Awareness’](/wms/GOV-POL-023#s’§Training and Awareness’)
AVSEC-COC-01	🟠 Ref-only	[OPS-PRO-001 §‘§9 Air-Cargo Security’](/wms/OPS-PRO-001#s’§9 Air-Cargo Security’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)	Reference-only watchpoint (P1.2 relevance adjudication 2026-06-19, CF). The s.44B(3) chain-of-custody duty bites only if Westlink takes custody of cargo after RACA clearance and before loading; CF confirmed Westlink never takes such custody — clearance and handover occur through the RACA’s controlled environment. Primary-source confirmed (ATSA s.44B(3) + s.9 ‘cleared’ definition). Evidence links to OPS-PRO-001 §9 / GOV-POL-023 retained as precautionary watchpoint coverage (the documents still address air-cargo security); full traceability un-wiring deferred as disproportionate to a watchpoint reclassification. Re-open to Applicable if Westlink ever takes custody of cleared air cargo.

Clause Aviation Transport Security Regulations 2005 Reg 4

ID	Coverage	Evidence	Gap	Notes
AVSEC-DEC-01	✅ Full	[OPS-PRO-001 §‘§9 Air-Cargo Security’](/wms/OPS-PRO-001#s’§9 Air-Cargo Security’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
AVSEC-DEC-02	✅ Full	[OPS-PRO-001 §‘§9 Air-Cargo Security’](/wms/OPS-PRO-001#s’§9 Air-Cargo Security’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause Aviation Transport Security Regulations 2005 — 90-day retention obligation on RACA; prudent mirror control for consignor

ID	Coverage	Evidence	Gap	Notes
AVSEC-REC-01	✅ Full	[OPS-PRO-001 §‘§9 Air-Cargo Security’](/wms/OPS-PRO-001#s’§9 Air-Cargo Security’) [GOV-POL-023 §‘§Records and Retention’](/wms/GOV-POL-023#s’§Records and Retention’)

Clause Civil Aviation Safety Regulations 1998 Part 92 + IATA Dangerous Goods Regulations

ID	Coverage	Evidence	Gap	Notes
AVSEC-DG-WP-01	🟠 Ref-only	—		Reference-only watchpoint — Westlink does not currently consign dangerous goods (confirmed operationally 2026-04-15). If air DG consignment commences, CASR Part 92 obligations activate as a direct shipper duty. Re-open this row alongside ADG/IMDG framework build (deferred per compliance library README DG watchpoint).

Clause Prudent control — no specific statutory obligation on consignors (ISO 9001 cl 8

ID	Coverage	Evidence	Gap	Notes
AVSEC-DD-01	🟡 Partial	[OPS-PRO-001 §‘§9 Air-Cargo Security’](/wms/OPS-PRO-001#s’§9 Air-Cargo Security’) [GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)	🟡 Medium	Control documented in OPS-PRO-001 §9 Air-Cargo Security (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (security-declaration records) accruing from the next operating cycle.

Rendered from frontmatter by scripts/render_compliance.py. Source extraction: scripts/extract_iso9001_requirements.py. Evidence population: scripts/populate_iso9001_evidence.py. Validate: scripts/compliance_validate.py.