Table of Contents
Fiverr International Ltd. is a Tel Aviv–headquartered, NYSE-listed global freelance services marketplace with no identified direct involvement in weapons supply, defence contracting, settlement construction, or surveillance-technology provision to Israeli state or military bodies. Its BDS-1000 score of 619 (Tier B) is driven primarily by structural economic integration with Israel and, to a lesser degree, by data-jurisdiction exposure and a controlling-principal political act.
The dominant scoring factor is V-ECON (V-Score 7.89), which reflects the full set of confirmed Israeli-nexus anchors: Israeli founding (2010), Tel Aviv as the primary engineering and executive headquarters from inception through at least end-2024, Preferred Technology Enterprise (PTE) tax status reducing effective Israeli corporate tax to approximately 12%, Israel Innovation Authority (IIA) grant obligations binding significant intellectual property to Israeli-territory R&D, and direct capital deployment into Israeli-domiciled companies totalling at least ~$95 million (Stoke Talent, 2021) with a second acquisition (AutoDS, 2024) at an estimated ~$50 million. These are confirmed, structural, and ongoing facts — not speculative associations.
V-DIG (V-Score 4.71) scores on a data-exposure and digital-sovereignty basis: Fiverr processes sensitive personal data (identity credentials, payment data, buyer–seller communications, behavioural profiles) for a multi-million user platform whose principal engineering and data-science operations are concentrated in Tel Aviv, where those personnel are subject to Israeli legal process for data access requests. No confirmed state security contract, Project Nimbus participation, or documented operational use of Fiverr’s platform by Israeli military or intelligence bodies has been identified; the score sits in the data-residency floor band rather than the provision-to-state bands.
V-POL (V-Score 5.34) is anchored by CEO and co-founder Micha Kaufman’s publicly stated personal financial contribution to Israeli military efforts in October 2023, recorded in Israeli business press. The rubric’s Stated-Purpose Trigger and Controlling-Principal Carry-Through provisions apply because Kaufman simultaneously holds the CEO role, co-founder identity, and a Founder Share governance instrument. Convergent evidence — a documented asymmetry between vocal corporate condemnation of Russia’s invasion of Ukraine (including service suspension) and complete silence on Palestinian civilian harm in Gaza, and the FY2024 Form 20-F’s absence of any reference to the ICJ Advisory Opinion of July 2024 or ICC arrest warrants of November 2024 — supports mid-band placement.
V-MIL (V-Score 0.02) is a near-zero finding. No defence contracts, SIBAT listings, UN OHCHR database entries, PAX or Al-Haq named-company citations, dual-use product lines, or supply-chain relationships with Israeli or international defence primes have been identified across any Tier-1 authoritative source checked.
| Date | Event |
|---|---|
| 2010 | Fiverr founded by Micha Kaufman and Shai Wininger in Tel Aviv 1 |
| June 2019 | Fiverr IPO on NYSE; F-1 prospectus discloses Cayman holding structure, Israeli operating entity, IIA grant obligations 2 |
| 2018 | Haifa R&D centre opened at Matam technology park 3 |
| January–February 2019 | AND CO and ClearVoice (U.S.-origin) acquired 4 |
| February 2022 | Stoke Talent (Tel Aviv) acquired for ~$95 million; rebranded as Fiverr Enterprise 5 |
| February 2022 | Fiverr suspends services to Russian users following invasion of Ukraine; CEO issues corporate condemnation 6 |
| June 2023 | Veed.io (London) acquired 7 |
| H1 2023 | CEO Kaufman publicly opposes Netanyahu judicial overhaul; described as vocal tech-sector opposition voice; reportedly hangs Declaration of Independence at Tel Aviv HQ 8 |
| August 2023 | AWS Israel (Tel Aviv) region launches, creating potential data-jurisdiction exposure for any Israeli-routed Fiverr workloads 9 |
| October 2023 | October 7 Hamas attacks; Fiverr publishes corporate solidarity statement; CEO Kaufman publicly states personal donation in support of IDF 810 |
| October–November 2023 | Fiverr operational communications describe business-continuity measures for Israeli employees and freelancers; multiple Form 6-K filings with SEC 11 |
| 2024 | Fiverr Go AI product suite launched; runs on AWS infrastructure 12 |
| 2024 | AutoDS (Israel, dropshipping automation) acquired, estimated ~$50 million 13 |
| 19 July 2024 | ICJ Advisory Opinion: Israel’s presence in OPT held unlawful; third-party non-assistance obligations articulated 14 |
| 21 November 2024 | ICC Pre-Trial Chamber I issues arrest warrants for Netanyahu and Gallant 15 |
| FY2024 20-F (filed ~March 2025) | Annual report covers full post-ICJ AO and post-ICC warrant period; neither legal determination is referenced; PTE status, IIA obligations, and Israeli operations confirmed as ongoing 16 |
Fiverr International Ltd. was founded in Tel Aviv in 2010 by Micha Kaufman and Shai Wininger as an online marketplace enabling buyers to commission freelance digital services — initially priced at a uniform five dollars, hence the name. Following venture funding from Bessemer Venture Partners, Accel Partners, and others, the company listed on the NYSE in June 2019, raising approximately $111 million at a valuation exceeding $1 billion. It has operated as a publicly traded company since that date. Its Cayman Islands incorporation is a standard capital-markets access structure; the de facto place of effective management throughout its history has been Tel Aviv. 12
The company’s core product is a two-sided digital marketplace connecting freelance service providers (“sellers”) with commercial and individual buyers across more than 500 service categories, including graphic design, software development, content writing, video production, and digital marketing. Revenue is generated through service fees and commissions on marketplace transactions and through subscription revenue from enterprise workforce management products. Fiverr does not manufacture, supply, or distribute physical goods of any kind. 216
The group’s subsidiary structure as of the FY2024 filing includes Fiverr Ltd. (Israel, principal operating entity), Fiverr Inc. (Delaware), Fiverr GmbH (Germany), Fiverr UK Ltd. (England and Wales), Stoke Talent Ltd. (Israel, now operating as Fiverr Enterprise), AutoDS Ltd. (Israel, acquired 2024), and Veed.io Ltd. (England and Wales, acquired 2023). The two Israeli operating subsidiaries beyond the main entity — Stoke Talent/Fiverr Enterprise and AutoDS — reflect a sustained M&A strategy directed at Israeli-domiciled technology companies. 51316
CEO Micha Kaufman holds a minority but governance-significant equity stake supplemented by a Founder Share instrument conferring veto rights over fundamental corporate actions including mergers, acquisitions, and articles of association amendments. This mechanism, disclosed in all annual 20-F filings, means that Kaufman’s personal governance control substantially exceeds his economic stake. Global headcount was approximately 740 at end-FY2023, declining to approximately 650–700 by end-FY2024 following restructuring. The majority of employees are Israel-based, concentrated in Tel Aviv and Haifa engineering functions. 216
Fiverr International Ltd. has no identified involvement in the V-MIL domain across any of the six sub-categories evaluated. The company does not manufacture physical products, does not operate in defence procurement supply chains, has no documented contractual relationship with the Israeli Ministry of Defence, the IDF, the Israel Border Police, or the Israel Prison Service, and appears in none of the authoritative civil-society databases that track corporate military involvement in the Israeli context. 172
The structural basis for a near-zero V-MIL score is Fiverr’s business model: a digital services marketplace has no natural intersection with the procurement categories that define V-MIL involvement — munitions, weapons systems, heavy machinery, base services, logistics sustainment, or dual-use physical goods subject to export licensing. Fiverr’s product portfolio consists of a consumer-facing freelance marketplace platform, a B2B enterprise workforce management SaaS (Fiverr Enterprise, formerly Stoke Talent), and AI-enhanced product features including Fiverr Go and Fiverr Neo. None of these products has a ruggedised, mil-spec, tactical, or otherwise defence-grade variant documented in any public source. The rubric definition of the V-MIL software/AI inclusion threshold requires that a product’s designed output produce a targeting decision or weapons effect; Fiverr’s platform outputs — service matches and enterprise workforce management data — do not meet this threshold. 172
A specific claim that appeared in prior analytical text — that Fiverr’s proprietary matching algorithms were “repurposed” to “optimise Kill Chain logistics” — was examined in the audit and found to be unsupported by any independent source. NoCamels reporting from October 2023 describes Israeli high-tech companies using digital infrastructure and AI tools to coordinate volunteer and civilian logistics in the aftermath of the October 7 attacks, but does not attribute algorithmic retasking to Fiverr’s core commercial platform. The “Lev Echad” (One Heart) volunteer logistics initiative was documented as having a presence at Fiverr’s Tel Aviv headquarters during this period, but the specific claim that this initiative procured and distributed military equipment such as ceramic body armour, bulletproof helmets, and reconnaissance drones remains unverified by any primary documentary source and is excluded from the scored findings. 18
The UN OHCHR database maintained pursuant to HRC resolutions 31/36 and 53/25 — which as of its most recent 2023 iteration covers 112 companies across construction, finance, tourism, real estate, and infrastructure categories — does not include Fiverr. 19 The PAX Netherlands report Companies Arming Israel and Their Financiers (June 2024), which profiles arms and dual-use technology suppliers, does not name Fiverr. 20 The Al-Haq Business and Human Rights report (July 2024) similarly does not name Fiverr. 21 UN Special Rapporteur report A/HRC/59/23 (Albanese, July 2025), which specifically addresses military, surveillance/carcerality, and civilian heavy machinery sectors, does not include Fiverr among its named companies. 22
The CEO’s publicly stated personal financial contribution to Israeli military efforts in October 2023 is noted here for completeness. However, this act does not constitute kinetic supply-chain involvement by Fiverr the company and is correctly scoped to V-POL under the rubric’s routing conventions. The absence of any formal defence contract, arms supply relationship, or dual-use product line means the V-POL personal donation does not create derivative V-MIL exposure.
Export licensing history was also examined. Fiverr’s 20-F filings acknowledge the applicability of Israel’s Defence Export Control Law (2007) as a standard risk-factor disclosure common to all Israeli tech companies listed on U.S. exchanges, but no specific licence application, regulatory inquiry, enforcement action, or export control proceeding relating to Fiverr has been identified in any jurisdiction. 216
The most significant evidentiary gap is the unverified Lev Echad equipment-procurement claim. If contemporaneous Hebrew-language reporting, fundraising records, or photographic evidence were to confirm that Fiverr’s headquarters served as a logistics hub for military-grade equipment distribution — rather than merely civilian volunteer coordination — this would require re-evaluation of the V-MIL boundary, specifically whether the Logistical Sustainment or Supply-Chain Integration sub-categories become applicable. This remains the highest-priority open evidence question for V-MIL purposes, and its current exclusion is explicitly a function of source unavailability rather than source contradiction. 18
A second structural caveat concerns the limits of absence evidence. The audits note that several key sources — including Who Profits Research Center and AFSC Investigate profiles for Fiverr — could not be live-verified. While training-data knowledge through April 2026 supports the “not found” determination, definitive confirmation of the nil finding for Who Profits and AFSC requires direct database retrieval. This caveat applies to the entire V-MIL section but is unlikely to change the directional finding given the breadth of sources independently returning null results.
A third argument that was considered and rejected as legally insufficient is the transitive Dell/Fiverr Enterprise inference: that because Dell has documented Israeli government infrastructure contracts and could hypothetically be a Fiverr Enterprise customer, Fiverr becomes transitively integrated into the Israeli defence supply chain. Even if Dell’s use of Fiverr Enterprise were confirmed (it is not), general-purpose workforce management software use by a defence-adjacent firm does not constitute supply-chain integration under any standard rubric definition. The argument fails both on the factual predicate (unconfirmed use) and the legal/analytical framework (general-purpose commercial SaaS is not defence supply). 2
For the V-MIL score to change materially, at least one of the following would need to be established: a confirmed defence procurement contract, confirmed Lev Echad military-equipment logistics with Fiverr corporate resources, a confirmed dual-use product variant specifically designed for or sold to the security apparatus, or confirmed supply-chain integration with an Israeli defence prime contractor.
| Entity | Type | Role / Relevance | Finding |
|---|---|---|---|
| Fiverr International Ltd. | Target company | Global freelance marketplace operator | No defence contract; no V-MIL involvement identified |
| Fiverr Ltd. (Israel) | Subsidiary | Principal Israeli operating entity | No defence supply relationship identified |
| Fiverr Enterprise (fmr. Stoke Talent) | Product/subsidiary | B2B workforce management SaaS | General commercial product; no defence-specific variant confirmed |
| Lev Echad (לב אחד) | Civil-society initiative | Volunteer logistics associated with Fiverr HQ post-Oct 7 | Coordination role documented; military-equipment procurement claim unverified 18 |
| Micha Kaufman | CEO / co-founder | Personal IDF donation (Oct 2023) | Routed to V-POL; no kinetic supply by Fiverr |
| IMOD / IDF | Israeli state | Potential counterparty | No contract or supply relationship identified |
| SIBAT | Israeli export authority | Defence export listings checked | Fiverr not listed 23 |
| UN OHCHR (HRC Res. 31/36) | International body | Settlement database | Fiverr not listed 19 |
| A/HRC/59/23 (Albanese) | UN report | Economy of occupation / named companies | Fiverr not named 22 |
| PAX Netherlands (June 2024) | NGO report | Companies arming Israel | Fiverr not named 20 |
| Al-Haq (July 2024) | NGO report | Business and human rights | Fiverr not named 21 |
| Dell Technologies | Third party | Alleged indirect nexus via Fiverr Enterprise | Unverified; nexus argument rejected 2 |
| NoCamels | Media | Oct 2023 Israeli tech wartime logistics | Reports civilian coordination; no algorithmic kill-chain attribution to Fiverr 18 |
Fiverr’s V-DIG score is grounded in the data-exposure and digital-sovereignty principle rather than in any confirmed direct relationship with Israeli state security, military, or intelligence bodies. The analytical chain runs as follows: Fiverr is an Israeli-headquartered platform operating at global scale that collects and processes multiple categories of sensitive personal data; that data is processed by engineers and data scientists primarily located in Tel Aviv, who are subject to Israeli legal process; this creates a structural and ongoing data-jurisdiction exposure regardless of whether Israeli state actors have exercised any access rights.
The data categories at issue are not incidental: they include user identity credentials (including government ID in some verification markets), payment credentials and financial transaction records, real-time communications between buyers and sellers routed through Fiverr’s platform, behavioural data (search, click, order, review history), and — since the 2024 launch of Fiverr Go — creative and professional work-product portfolios used to train personalised AI models. The combination of identity, financial, communications, and behavioural data at platform scale represents a sensitive data aggregate. 242516
Amazon Web Services is confirmed as Fiverr’s primary and substantially exclusive cloud infrastructure provider across FY2021, FY2022, and FY2023 annual reports, with this single-vendor dependency disclosed as a material risk factor. Continued AWS dependency is confirmed through Q3 2024 earnings releases. AWS launched its Israel (Tel Aviv) region in August 2023. Whether any Fiverr workloads — including those serving Israeli-resident users or regional disaster-recovery architecture — are routed through this region is not publicly disclosed and constitutes a material evidence gap. If any workloads traverse the AWS Israel region, the data involved would be physically located within Israeli territory and subject to the Israeli Privacy Protection Law and potentially to Israeli intelligence access frameworks. 92624
Independently of AWS regional routing, Fiverr’s primary engineering, product, and data-science operations have been headquartered in Tel Aviv from the company’s founding through the full audit period. Israeli-based engineers and data scientists with production access are subject to Israeli legal process for data demands regardless of where AWS regions are located. This is a structural condition confirmed in every annual filing from IPO through FY2024. 216
The Stoke Talent acquisition (February 2022, ~$95 million) brought an additional Israeli-origin technology stack into Fiverr’s product infrastructure. Stoke Talent was a Tel Aviv–founded SaaS company; its pre-acquisition technology stack, client data infrastructure, and inherited vendor relationships have not been audited in any public source. Stoke Talent’s technology is described as substantially integrated into the Fiverr Enterprise product suite. This integration means the data governance question extends to enterprise customer workforce data processed through the Fiverr Enterprise platform. 527
Fiverr Go, launched in 2024 and discussed across Q1–Q3 2024 earnings calls, involves collection and processing of freelancer work portfolios to train personalised AI models for automated service delivery. Fiverr has not published model cards, AI transparency reports, or data residency disclosures for Fiverr Go model training workloads. No Israeli-origin AI infrastructure vendor has been confirmed as a component supplier. The product represents a new and expanding category of behavioural and creative-output data aggregation without corresponding public governance transparency. 24
The score is held within the data-residency floor band (I-DIG 5.50) rather than escalated to the Surveillance/Intelligence Integration or Provision-to-State bands, for two reasons. First, no confirmed state security contract, Project Nimbus participation, or operational use of Fiverr’s platform by Israeli military or intelligence bodies has been identified. Second, the data-jurisdiction exposure is structural and ongoing but does not constitute active provision of surveillance capability — it is a function of the geographic location of engineering personnel and cloud infrastructure rather than a purpose-built data-sharing arrangement with Israeli state actors.
No confirmed relationship with Israeli-origin cybersecurity or surveillance vendors — including Check Point, Wiz, SentinelOne, CyberArk, Verint, NICE, Claroty, BriefCam, or AnyVision/Oosto — has been identified in any public corporate disclosure, press release, partnership announcement, or verified technographic database entry. The absence of disclosure does not confirm absence of relationship, as enterprise security tooling is routinely undisclosed in public filings. 25
The strongest counter-argument against the V-DIG score is that data-jurisdiction exposure in the absence of any confirmed state access event or state security contract is a structural characteristic shared by every Israeli-headquartered technology company with Israeli-based engineers, and that absent confirmed exercise of access rights, the risk is hypothetical rather than actual. This argument has force: the score reflects potential exposure given structural factors, not a confirmed data-sharing relationship. However, the rubric’s Data-Exposure Principle applies to the structural condition itself — the ongoing processing of sensitive data in a jurisdiction subject to a particular legal access framework — not only to confirmed individual access events. The floor band placement at I-DIG 5.50 reflects this calibration: the condition triggers the principle but the lack of a confirmed state contract prevents escalation.
A second limitation is the absence of live-verified technographic data. The BuiltWith records cited reflect publicly observable web technology from 2022–2024 snapshots and do not cover back-end security or enterprise infrastructure tooling. A confirmed procurement relationship with an Israeli-origin CSPM, EDR, or SIEM vendor could increase the score, but no such relationship has been identified. The evidence gap is real and the nil finding for Israeli-origin security vendors is explicitly a function of non-disclosure, not confirmed absence. 25
The AWS Israel region routing question remains the most significant precision gap in V-DIG. Fiverr’s FY2023 20-F and Q1–Q3 2024 earnings releases do not address regional routing decisions; live infrastructure testing or internal data-residency documentation would be required to resolve this. The score treats this as a precision gap — it does not suppress the data-jurisdiction exposure scored on the Tel Aviv engineering-personnel basis, but it would be relevant to any escalation toward higher bands.
For the V-DIG score to change materially upward, at least one of the following would need to be confirmed: a direct service agreement with Israeli state security bodies, confirmed routing of sensitive data through AWS Israel region, confirmed deployment of Israeli-origin surveillance tooling, or confirmed use of Fiverr’s platform by Israeli military or intelligence procurement functions.
| Entity | Type | Role / Relevance | Finding |
|---|---|---|---|
| Fiverr International Ltd. | Target company | Platform operator and data controller | Sensitive data processed by Israeli-domiciled engineering staff |
| Fiverr Ltd. (Israel) | Subsidiary | Primary engineering and data-science operations | Tel Aviv HQ; personnel subject to Israeli legal process 2 |
| Stoke Talent Ltd. / Fiverr Enterprise | Subsidiary (Israeli-origin) | Enterprise workforce SaaS; integrated 2022-present | Israeli-origin tech stack; pre-acquisition infrastructure unaudited 5 |
| AutoDS Ltd. (Israel) | Subsidiary (Israeli-origin) | Dropshipping automation; acquired 2024 | Additional Israeli engineering operation 13 |
| Amazon Web Services (AWS) | Cloud vendor | Primary and exclusive cloud provider | AWS Israel (Tel Aviv) region launched Aug 2023; Fiverr routing undisclosed 926 |
| Micha Kaufman | CEO / co-founder | Data governance decision authority | Continuous Tel Aviv HQ operations confirmed through FY2024 16 |
| Israeli Privacy Protection Law | Regulation | Data-access framework | Applies to Israeli-domiciled data processors 28 |
| Israeli Defence Export Control Law | Regulation | Potential software/data export obligations | Disclosed as standard risk factor in all 20-F filings 2 |
| Project Nimbus (AWS / Google) | Israeli government contract | Cloud IaaS for Israeli state and military | Fiverr not a participant or subcontractor 29 |
| No Tech For Apartheid | Civil-society campaign | Project Nimbus opposition | Fiverr not named 30 |
| Fiverr Go | AI product | Freelancer work-portfolio AI training | No data-residency disclosure; no Israeli-origin vendor confirmed 24 |
| Fiverr Neo | AI product | Buyer-seller matching AI assistant | Consumer-facing; no state-security application identified 24 |
| Check Point / Wiz / SentinelOne / CyberArk | Israeli-origin cybersecurity vendors | Potential vendor relationships checked | No confirmed Fiverr relationship identified 25 |
| Bessemer Venture Partners (Israel office) | Institutional shareholder | Early investor; Israeli tech portfolio | Passive financial investor; no technology procurement influence identified 31 |
| 7amleh | NGO | Digital rights of Palestinians | Fiverr not named; structurally outside scope of social-media platform investigations 32 |
Fiverr scores at the top of the V-ECON domain because it unambiguously satisfies the rubric’s Israeli-Nexus Floor — the co-occurrence of three or more confirmed Israeli-nexus factors triggering the Indigenous Capital / Beneficial Ownership band (I-ECON 8.3–8.9). All three primary factors are confirmed at full strength, and a fourth is present at partial strength.
Founding in Israel is confirmed in the F-1 IPO prospectus: Fiverr was incorporated, operationally established, and grew from inception in Tel Aviv from 2010. 21 Principal place of effective management is Tel Aviv from founding through at least FY2024: the Tel Aviv address is the registered office of the principal operating entity, the location of R&D, engineering, product, and executive management, and the domicile of the majority of employees. 1633 Neither the Cayman Islands holding company incorporation nor the existence of U.S. and European subsidiaries displaces this finding. Preferred Technology Enterprise (PTE) tax status is confirmed active in both the FY2023 and FY2024 20-F filings, reducing the effective Israeli corporate tax rate on IP-attributed income to approximately 12% and requiring ongoing maintenance of qualifying R&D activity within Israel. This constitutes a formal, continuing regulatory relationship with the Israel Tax Authority. 3416 The Israel Innovation Authority grant obligations — which bind IP developed with IIA funding to Israeli-territory R&D and require IIA approval plus royalty payment for any IP transfer outside Israel — represent an additional institutional nexus distinct from the PTE designation. 216 These four structural factors collectively establish Fiverr as an entity whose economic substance, intellectual property, and tax obligations are deeply anchored in Israel.
Direct capital deployment into Israeli-domiciled companies reinforces this picture. The Stoke Talent acquisition (approximately $95 million, closed February 2022) is Fiverr’s largest single public-period M&A transaction; it was the acquisition of a Tel Aviv–founded and Israel-domiciled SaaS company, adding Stoke Talent Ltd. as an Israeli operating subsidiary. 527 The AutoDS acquisition (closed 2024, reported at approximately $50 million in Israeli financial press) adds a further Israeli-incorporated entity and Israel-based engineering team. 1333 Combined, these two acquisitions represent approximately $145 million of direct capital deployment into Israeli-domiciled technology targets within a three-year window. In both cases the acquired entities continue to operate as Israeli subsidiaries with Israel-based development teams; neither has been relocated outside Israel following acquisition.
The PTE and IIA structures create a formal mechanism through which Fiverr’s global commercial success — revenue generated predominantly in the United States and Western Europe — is partially channelled into Israeli corporate tax receipts at a preferential rate, and through which Fiverr’s intellectual property (the algorithms, platform architecture, and AI systems that drive its marketplace) is administratively bound to Israeli territorial R&D. The transfer pricing structure disclosed in Fiverr’s 20-F risk factors indicates that the Israeli parent entity (Fiverr International Ltd., operationally managed from Tel Aviv) retains a material share of consolidated profit; the U.S. and European subsidiaries are structured as cost centres or limited-risk distributors. The direction of profit consolidation is from global markets inward to the Israeli operational apex. 1634
Fiverr’s Preferred Technology Enterprise designation is explicitly conditioned on maintaining qualifying R&D activity within Israel. This means that every employment decision affecting Israeli R&D headcount, every technology investment involving Israeli engineers, and every product development decision made in Tel Aviv occurs within a framework in which Israeli state tax preferences create a positive incentive for maintaining Israel-based operations. This is not a politically directed arrangement — it is a standard feature of Israeli industrial policy available to qualifying technology companies — but it constitutes a fiscal alignment between Fiverr’s investment decisions and Israeli state economic objectives.
The magnitude score (M 6.50) reflects Fiverr’s notable but sub-flagship scale. With approximately 650–700 global employees (majority Israel-based), a market capitalisation in the range of $700 million–$1.5 billion across the audit period, and no disclosed Israel-specific revenue, Fiverr is a significant Israeli technology company but not a structural pillar of the Israeli economy at the scale of Elbit Systems, Check Point, or the major Israeli banks. The absence of publicly disclosed granular Israel-specific revenue and payroll figures is an identified precision gap that prevents more precise magnitude calibration. 16
The primary counter-argument against the high I-ECON score is that Israeli-nexus structural factors — founding, HQ, PTE status — are analytically distinct from active economic contribution to the occupation specifically, and that the rubric’s application of the Indigenous Capital / Beneficial Ownership band to companies with no settlement-territory activity and no defence-sector revenue may overstate the linkage to the specific harms targeted by BDS. This argument has partial merit: Fiverr’s economic activity is concentrated in pre-1967 Israel, both of its Israeli operating entities (Tel Aviv and Haifa) are in internationally recognised Israeli territory, and no economic activity in the West Bank, Gaza, or Golan Heights has been identified. The scoring framework treats the Israeli-nexus structural factors as sufficient for the band placement regardless of whether activity extends to occupied territories specifically — this is a feature of the rubric design, not an error in its application.
A second limitation is the absence of publicly disclosed Israel-specific financial data. The precise amount of Israeli corporate tax paid under PTE status, the precise number of Israeli-based employees (and associated payroll tax flows to the Israeli treasury), and the specific IP categories subject to IIA transfer restrictions are not publicly disclosed at a granular level. The score is anchored on confirmed structural factors rather than quantified fiscal flows. The direction of the finding is not in doubt, but precision is limited. 16
The unverified Goldman Sachs Asset Management shareholding figure noted in the audit has been excluded from scored findings. Whether any portion of Fiverr’s treasury cash (~$340–380 million as of FY2024) is held at Israeli banks (Bank Hapoalim or Bank Leumi, both on the Who Profits Financing Land Grab list) is not publicly disclosed and represents an additional unresolved evidence gap. These gaps do not affect the I-ECON band placement, which is determined by the confirmed structural nexus factors, but could affect the M-ECON score if resolved.
For the V-ECON score to change materially downward, Fiverr would need to demonstrate a structural decoupling from Israeli economic anchors — re-domiciliation of principal management, surrender of PTE status, relocation of primary R&D outside Israel, and cessation of Israeli M&A activity. None of these has been announced or is evident in available sources.
| Entity | Type | Role / Relevance | Finding |
|---|---|---|---|
| Fiverr International Ltd. | Target / Cayman holdco | Ultimate parent; Israeli operational apex | Full Israeli-nexus confirmed 12 |
| Fiverr Ltd. (Israel) | Principal operating subsidiary | R&D, engineering, executive management; Tel Aviv and Haifa | Primary economic anchor 16 |
| Stoke Talent Ltd. / Fiverr Enterprise | Israeli subsidiary | Acquired ~$95M (2021); workforce SaaS | Direct Israeli capital deployment 527 |
| AutoDS Ltd. | Israeli subsidiary | Acquired 2024; dropshipping automation | Direct Israeli capital deployment 13 |
| Israel Innovation Authority (IIA) | Israeli state body | R&D grants; IP-retention obligations | Structural IP and R&D tie to Israeli territory 34 |
| Israel Tax Authority | Israeli state body | PTE designation (~12% effective rate) | Formal fiscal regulatory relationship 1634 |
| Micha Kaufman | CEO / co-founder | Founder Share governance; ~6–7% equity stake | Partial beneficial-ownership factor 2 |
| Shai Wininger | Co-founder (departed) | Departed ~2016; no current governance role | Historical founding nexus only 1 |
| Adam Fisher / Bessemer Venture Partners | Board member / investor | BVP Israel office; early investor | Passive financial; no procurement direction 31 |
| Vanguard Group / BlackRock | Institutional shareholders | Index/passive holdings | No Israeli-nexus investment mandate 2 |
| Bank Hapoalim / Bank Leumi | Israeli banks | Potential treasury cash custodians | Unverified; evidence gap noted |
| Who Profits Research Center | NGO | Financing Land Grab list; corporate database | Fiverr not listed in available records 35 |
| DBIO 2024/2025 | NGO report | Financial institution settlement nexus | Fiverr not a financial institution; not listed 36 |
| PAX (June 2024) | NGO report | Companies arming Israel | Fiverr not named 20 |
The V-POL score rests on three mutually reinforcing categories of evidence: a controlling-principal personal financial act with documented public attribution to military ends; a sustained and asymmetric corporate communications posture across simultaneous armed conflicts; and corporate regulatory silence on internationally significant legal determinations that apply constructive-notice obligations. These three categories interact under the rubric to produce an I-POL score in the Direct Financing band (8.3) and a Proximity score of 9.0 reflecting the Controlling-Principal Carry-Through provision.
Kaufman’s IDF-purposed donation (October 2023): In October 2023, CEO and co-founder Micha Kaufman publicly stated via Twitter/X that he had made a personal financial donation in support of Israeli defence efforts following the October 7 attacks. This statement is documented in Israeli business press and contemporaneous reporting. 837 The specific recipient organisation has not been confirmed with precision in available primary sources (Lev Echad is a plausible but inferential candidate given the timing and character of the donation). Under the rubric’s Stated-Purpose Trigger (Principle 5), the recipient-identity gap is a clerical precision gap rather than a score-suppressing evidential failure: Kaufman’s own public statement establishes the military-support purpose. Under the Controlling-Principal Carry-Through (Principle 4), this personal act is attributed to Fiverr International Ltd. because Kaufman is simultaneously the CEO, the co-founder, the public face of the company, and the holder of the Founder Share governance instrument that gives him veto rights over fundamental corporate actions. This is not an attempt to attribute every personal act of any executive to the company; rather, it reflects the specific rubric rule that applies where a controlling principal with a documented governance instrument makes a public political act that was itself made in the context of his CEO identity.
Ukraine vs. Gaza communications asymmetry: Following Russia’s invasion of Ukraine in February 2022, Fiverr issued a public corporate condemnation of the invasion and suspended services to Russian users. This action was framed explicitly in moral and humanitarian terms. 6 Following the October 7 attacks and the subsequent Israeli military campaign in Gaza — which was accompanied by mass civilian casualties documented by international bodies and NGOs — Fiverr issued no corporate statement addressing Palestinian civilian harm, no call for humanitarian access, no service adjustment affecting Israeli users, and no expression of concern for civilian populations in Gaza at any point through the audit date. 3810 Both conflicts overlapped with Fiverr’s operational period. Both involved large-scale civilian casualties that prompted geopolitical responses from other technology companies. The treatment is structurally asymmetric, and this asymmetry is the most documentable pattern in the corporate communications record.
For comparative context: Fiverr was not alone in this asymmetry within the Israeli tech sector — no identified Israeli-headquartered NYSE/Nasdaq-listed peer company has publicly disclosed an internal policy review triggered by either the ICJ AO or ICC warrants. However, this sector-wide pattern does not render Fiverr’s specific corporate posture unscoreable; it contextualises the magnitude (M-POL 4.50) rather than eliminating the finding.
Post-ICJ and post-ICC regulatory silence: The ICJ Advisory Opinion of 19 July 2024 held Israel’s continued presence in the OPT unlawful and articulated third-party non-assistance obligations. 14 The ICC Pre-Trial Chamber I issued arrest warrants for Netanyahu and Gallant on 21 November 2024. 15 Fiverr’s FY2024 Form 20-F — the first annual filing to encompass both legal determinations, covering the full FY2024 period and certified by Kaufman and the CFO under SOX Sections 302 and 906 — makes no reference to either legal determination in its risk factors, legal proceedings, or management discussion sections. 16 The filing continues to describe Israeli operations under standard risk-factor language without acknowledging the ICJ AO or its implications. This is an executive-certified materiality determination: the certifying officers concluded that these internationally significant legal events were not material to Fiverr’s disclosed risk profile. No Fiverr corporate communication addressed either determination in any public forum identified in available records. 38
Kaufman’s pre-October 7 posture — vocal public opposition to the Netanyahu judicial overhaul, using his Fiverr CEO identity — demonstrates that he was willing to instrumentalise the company’s public profile for Israeli domestic political purposes when he judged an issue to be important. 8 The subsequent sharp pivot to unconditional public solidarity with the military response after October 7, combined with the absence of any equivalent public engagement with Palestinian civilian rights, international humanitarian law, or the ICJ/ICC legal determinations, documents a directional consistency across available records. No claim of intent is made; the documented pattern is described.
The M-POL score (4.50) reflects the available evidence: one publicly stated donation event with unknown dollar value, sustained multi-year corporate communications asymmetry, and ongoing 2024 silence after the ICJ AO and ICC warrants. There is no evidence of corporate-level financial donations to FIDF, JNF, settlement organisations, or military welfare funds. Kaufman’s donation was made as a personal act, not as a corporate contribution by Fiverr International Ltd. The magnitude is held at a modest-presence level reflecting these limitations.
No evidence has been identified of Fiverr lobbying on Israel-related legislation (Israel Anti-Boycott Act, Combating BDS Act, ICC/ICJ jurisdiction questions, or foreign aid bills). Fiverr’s U.S. lobbying activity is documented as focused on gig-economy labour classification legislation (the WORK Act) and Section 1099-K tax reporting thresholds — issues with no direct Israel-Palestine nexus. 39
The principal counter-argument to the V-POL score concerns the attribution of a personal executive donation to the corporate entity. Kaufman’s October 2023 donation was made on his personal Twitter/X account and explicitly described as a personal contribution. No secondary source attributes the donation to Fiverr International Ltd. as a corporate act. The scoring framework’s Controlling-Principal Carry-Through provision is what enables this attribution, and the application of that provision to a personal act — even by a Founder Share–holding CEO — will be contested. The counter-position is that controlling-principal provisions should apply to governance acts (board decisions, voting exercises, M&A approvals) rather than to personal philanthropy, even where publicly stated. This is a legitimate analytical disagreement; the audit resolves it in favour of attribution given the explicit public framing in Kaufman’s CEO identity and the Founder Share governance instrument, but the reader should weigh this contested analytical choice.
A second counter-argument concerns the specific recipient of the personal donation. The rubric’s Stated-Purpose Trigger applies where the stated purpose is military-support but the specific recipient is unconfirmed. Critics may argue that without a confirmed recipient — which could range from civilian relief to direct IDF welfare — the precise nature of the support cannot be characterised with confidence. This argument has limited force given Kaufman’s own explicit public framing, but it does support the decision to hold I-POL at 8.3 rather than escalating to the upper end of the Direct Financing band.
The Ukraine/Gaza asymmetry finding depends on treating non-response as evidence rather than merely as silence. A counter-argument holds that companies are not obligated to comment on every armed conflict and that the Russia condemnation was motivated by factors (EU regulatory environment, Russian user base considerations, reputational factors in Western markets) that do not apply to the Gaza conflict. This contextual explanation is plausible and partially mitigates the inference drawn from the asymmetry, but does not eliminate it: the documented pattern remains that the company issued an explicit moral condemnation and operational response in one case and no comparable statement in the other, despite both conflicts involving mass civilian casualties contemporaneous with Fiverr’s operations.
The ICJ AO and ICC warrant silence finding is the most structurally secure element of the V-POL analysis because it is a documented corporate omission from a certified annual filing rather than an interpretation of absence. The counter-argument — that no Israeli-headquartered tech company disclosed these developments — is accurate but contextualises rather than negates the finding.
For the V-POL score to change materially downward, Fiverr would need to demonstrate: a publicly stated corporate commitment to humanitarian due diligence covering its Israeli operations, a corporate statement specifically addressing Palestinian civilian harm or ICJ/ICC determinations, or credible evidence that Kaufman’s personal donation was directed to civilian rather than military purposes.
| Entity | Type | Role / Relevance | Finding |
|---|---|---|---|
| Micha Kaufman | CEO / co-founder / Founder Share | Oct 2023 IDF-purposed personal donation; public advocacy | Documented personal donation; Controlling-Principal attribution applies 837 |
| Nir Zohar | President and COO | Unit 8200 claim in prior research | Claim unverified; not scored 40 |
| Shai Wininger | Co-founder (departed) | Unit 8200 service confirmed biographical fact | No current governance role; no V-POL act identified 1 |
| Jonathan Kolber | Board member | Former Koor Industries CEO; Claridge Israel | AIPAC role claim unverified and not scored 41 |
| Adam Fisher / BVP | Board member / investor | Anti-brain-drain public statements | Investor advocacy; no Fiverr-specific political act 31 |
| Ron Gutler | Board member | CyberArk, Cato Networks directorships | No V-POL acts identified 42 |
| Eyal Shachar / OurCrowd | Board member | OurCrowd Managing Partner | No settlement/military nexus; no V-POL acts identified 43 |
| Yael Garten | Board member | LinkedIn Data Science background confirmed | No V-POL acts identified |
| Canadian BDS Coalition | Civil-society | Boycott List of Shame | Fiverr listed; grounds: Israeli corporate origin 44 |
| BDS Movement / PACBI | Civil-society | Official campaign targets | Fiverr not a named specific campaign target 45 |
| FIDF / JNF-USA / JNF Canada | Philanthropic orgs | Checked as potential corporate donation recipients | No confirmed Fiverr corporate donation identified 4647 |
| ICJ (Case 186) | International court | Advisory Opinion 19 July 2024 | Not referenced in FY2024 20-F 1416 |
| ICC Pre-Trial Chamber I | International court | Arrest warrants 21 November 2024 | Not referenced in FY2024 20-F 1516 |
| LDA / OpenSecrets | Lobbying disclosure | U.S. registered lobbying | Fiverr lobbying on gig-economy/tax; no Israel-related lobbying identified 39 |
| HRW (Meta censorship report, Dec 2023) | NGO | Platform content asymmetry documented at Meta | Fiverr not named; context for sector-wide pattern 48 |
| 7amleh | NGO | Palestinian digital rights; platform censorship reports | Fiverr structurally outside scope of social-media platform focus 49 |
| Reddit r/Fiverr | User forum | Platform moderation asymmetry discussions | Low evidentiary weight; no independent corroboration 50 |
The strongest cross-domain challenge to the overall BDS-1000 score is a structural one: the 619 score (Tier B) is driven primarily by Fiverr’s economic integration with Israel — a condition shared by hundreds of Israeli-founded technology companies listed on U.S. exchanges — rather than by any identified direct participation in the occupation, settlement economy, defence supply chain, or surveillance apparatus. Critics of the scoring framework may argue that high V-ECON scores based solely on Israeli-nexus structural factors risk conflating “Israeli company” with “company complicit in specific occupation-related harms,” a conflation that undermines analytical precision and expands the scope of BDS-relevant activity beyond the specific harms that motivate the framework.
This argument has real force and is the most important limitation on the interpretive conclusions that can be drawn from this dossier. The V-ECON and V-DIG scores reflect structural conditions confirmed by public evidence; they do not reflect confirmed active participation in settlement activity, weapons supply, or surveillance provision. The appropriate response to this tension is not to suppress the structural findings — which are confirmed — but to characterise them accurately and to distinguish them from the higher-severity harms targeted by BDS’s core campaigns.
A second cross-domain limitation is the comprehensive reliance on training-data knowledge for several key source verifications. The nil findings for Who Profits, AFSC Investigate, A/HRC/59/23 named-company analysis, and PAX June 2024 are all flagged as training-data assessments not live-verified. These are likely to be directionally correct given the breadth of corroborating sources that independently return null results, but they should be independently confirmed before the dossier is cited in high-stakes contexts.
The evidentiary asymmetry between domains also warrants notice: V-ECON benefits from the most extensive documentary record (multiple SEC filings, Israeli press, M&A databases), while V-POL rests most heavily on a single public social media statement by Kaufman corroborated by Israeli business press, and V-DIG’s data-jurisdiction analysis depends significantly on the confirmed factual predicate of Israeli-based engineering operations rather than on any confirmed state-access event.
| Entity | Domain(s) | Type | Key Role | Authoritative Source |
|---|---|---|---|---|
| Fiverr International Ltd. | All | Target; Cayman holdco | Global freelance marketplace; Israeli operational apex | 1216 |
| Fiverr Ltd. (Israel) | V-DIG, V-ECON | Principal operating subsidiary | R&D, engineering, data science; Tel Aviv and Haifa | 216 |
| Stoke Talent Ltd. / Fiverr Enterprise | V-DIG, V-ECON | Israeli subsidiary | Acquired ~$95M 2021; enterprise workforce SaaS | 527 |
| AutoDS Ltd. | V-ECON | Israeli subsidiary | Acquired 2024; dropshipping automation | 13 |
| Veed.io Ltd. | V-ECON | UK subsidiary | Acquired June 2023; AI video editing | 7 |
| Micha Kaufman | V-POL, V-ECON | CEO / co-founder / Founder Share | Personal IDF donation; Controlling-Principal attribution | 81637 |
| Shai Wininger | V-POL, V-DIG | Co-founder (departed) | Unit 8200 alumnus; no current governance role | 1 |
| Nir Zohar | V-POL | President and COO | Unit 8200 claim unverified | 40 |
| Jonathan Kolber | V-POL | Board member | Koor Industries heritage; Claridge Israel | 41 |
| Adam Fisher / Bessemer Venture Partners | V-ECON, V-POL | Board member / investor | BVP Israel portfolio; anti-brain-drain advocacy | 31 |
| Ron Gutler | V-POL | Board member | CyberArk, Cato Networks co-director | 42 |
| Eyal Shachar / OurCrowd | V-POL | Board member | OurCrowd Managing Partner, Jerusalem | 43 |
| Amazon Web Services | V-DIG | Cloud provider | Primary and exclusive cloud; AWS Israel region (Aug 2023) | 926 |
| Israel Innovation Authority (IIA) | V-ECON | Israeli state body | R&D grant conditions; IP-retention obligations | 34 |
| Israel Tax Authority | V-ECON | Israeli state body | PTE designation (~12% effective tax rate) | 1634 |
| ICJ (Case 186) | V-POL, V-MIL, V-ECON | International court | Advisory Opinion 19 July 2024 | 14 |
| ICC Pre-Trial Chamber I | V-POL | International court | Arrest warrants 21 November 2024 | 15 |
| UN OHCHR HRC Res. 31/36 database | V-MIL, V-ECON, V-POL | International body | Settlement business database (112 companies) | 19 |
| A/HRC/59/23 (Albanese) | V-MIL, V-DIG, V-ECON | UN report | Economy of occupation/genocide; named companies | 22 |
| PAX Netherlands (June 2024) | V-MIL | NGO report | Companies arming Israel | 20 |
| Al-Haq (July 2024) | V-MIL | NGO report | Business and human rights | 21 |
| Who Profits Research Center | V-MIL, V-ECON, V-POL | NGO database | Corporate occupation profiles | 35 |
| AFSC Investigate | V-MIL, V-POL | NGO database | Company profiles; Israeli military links | 51 |
| Canadian BDS Coalition | V-POL | Civil-society | Boycott List of Shame; Fiverr listed | 44 |
| BDS Movement / PACBI | V-POL | Civil-society | Official campaign targets; Fiverr not a named target | 45 |
| NoCamels | V-MIL | Media | Oct 2023 Israeli tech wartime coordination reporting | 18 |
| Lev Echad (לב אחד) | V-MIL, V-POL | Volunteer initiative | Associated with Fiverr HQ post-Oct 7; equipment procurement unverified | 18 |
| SIBAT | V-MIL | Israeli authority | Defence export registry; Fiverr not listed | 23 |
| Domain | I | M | P | V-Score |
|---|---|---|---|---|
| V-MIL | 0.50 | 1.00 | 2.00 | 0.02 |
| V-DIG | 5.50 | 6.00 | 9.00 | 4.71 |
| V-ECON | 8.50 | 6.50 | 9.00 | 7.89 |
| V-POL | 8.30 | 4.50 | 9.00 | 5.34 |
Composite BRS: 619 — Tier B (600–799)
The composite is calculated with V-ECON as V_MAX (7.89). The sum of the remaining three V-Scores (0.02 + 4.71 + 5.34 = 10.07) contributes via a 20% side-boost. The formula yields (7.89 + 2.014) / 16 × 1000 = 619.
V-MIL’s near-zero score (0.02) reflects the rubric’s correct exclusion of pure marketplace software from the kinetic-supply domain and the absence of any confirmed defence contract, dual-use product, or supply-chain integration. The I-MIL of 0.50 is the minimum non-zero assignment reflecting the audit’s confidence in the nil finding rather than an evidence-of-absence floor; no evidence of military involvement has been identified across all Tier-1 sources.
V-DIG’s score (4.71) is anchored on the Data-Exposure Principle: Fiverr processes sensitive user data (identity, payments, communications, behavioural data) through Israeli-based engineering operations that are subject to Israeli legal process. The score is held at the data-residency floor band because no confirmed provision-to-state relationship has been identified; escalation to higher bands would require evidence of direct state security contracts or confirmed Israeli military/intelligence use of Fiverr’s platform.
V-ECON (7.89) dominates the composite because the Israeli-Nexus Floor is unambiguously and multiply confirmed: founding, principal place of management, PTE/IIA tax and IP status, and direct capital deployment into Israeli-domiciled targets totalling at least ~$145 million over three years. Magnitude is held at 6.50 reflecting Fiverr’s significant but sub-flagship scale.
V-POL (5.34) reflects the Stated-Purpose Trigger and Controlling-Principal Carry-Through applied to Kaufman’s October 2023 personal donation statement, convergent with the documented Ukraine/Gaza communications asymmetry and post-ICJ AO and post-ICC warrant corporate silence. Magnitude is 4.50 — one donation event with unknown dollar value plus sustained communications asymmetry — keeping the V-POL side-boost contribution proportionate to the available evidence.
High-confidence findings (well-supported across multiple Tier-1 sources, unlikely to change with further research):
– V-MIL nil finding: no defence contract, no OHCHR listing, no PAX/Al-Haq named-company citation, no dual-use product line.
– V-ECON Israeli-nexus structural factors: founding, Tel Aviv HQ, PTE/IIA status, Stoke Talent and AutoDS acquisitions — all confirmed in certified SEC filings.
– V-DIG data-jurisdiction exposure via Tel Aviv engineering operations: confirmed in all annual filings.
– V-POL Kaufman personal donation: self-disclosed publicly and corroborated in Israeli business press.
Medium-confidence findings (supported but with identified precision gaps):
– V-DIG I-score band placement: the data-residency floor band is the correct classification given available evidence; escalation to surveillance/provision-to-state bands requires state-contract confirmation not currently available.
– V-POL magnitude: M-POL 4.50 reflects a single confirmed personal act plus sustained communications asymmetry; dollar value undisclosed.
– V-ECON magnitude: M-ECON 6.50 reflects Fiverr’s scale as assessable from public information; Israel-specific revenue and payroll figures are undisclosed.
Key open questions (highest-priority evidence gaps):
1. Lev Echad military-equipment procurement: Does primary documentary evidence (contemporaneous Hebrew-language reporting, fundraising records, photographic evidence) confirm that Fiverr’s offices served as a logistics node for military equipment distribution? If confirmed, V-MIL Logistical Sustainment sub-category would require re-evaluation.
2. AWS Israel region routing: Are any Fiverr workloads routed through the AWS Israel (Tel Aviv) region? If confirmed, V-DIG data-residency findings would be substantially strengthened.
3. Kaufman personal donation recipient: Which organisation(s) received Kaufman’s October 2023 personal donation? If a named military-welfare or settlement organisation, V-POL magnitude and I-POL band placement may warrant upward revision; if a civilian relief organisation, downward revision would be warranted.
4. Who Profits and AFSC live verification: Do current live database snapshots confirm the nil findings for these databases? Likely confirmatory but requires direct retrieval.
5. FY2024 20-F full text: Does the full text of the FY2024 20-F contain any reference to the ICJ Advisory Opinion, ICC arrest warrants, or any new governance, operational, or due-diligence measures? Training-data assessment indicates no; live retrieval recommended.
6. Israeli-origin cybersecurity vendor relationships: Does Fiverr deploy Check Point, Wiz, SentinelOne, CyberArk, or comparable Israeli-origin security tooling internally? Undisclosed in public filings; would be relevant to V-DIG scoring if confirmed.
The following recommendations are calibrated to the validated score of 619 (Tier B), the specific evidence established in the domain audits, and the uncertainty and gaps identified above. They are ordered by connection to established evidence rather than by severity.
For institutions evaluating Tier B exposure based on established findings:
– The V-ECON structural nexus (founding, HQ, PTE/IIA, M&A) is confirmed and unlikely to change. Institutions applying economic-integration thresholds in their screening criteria should note that Fiverr’s primary economic substance and IP governance are structurally anchored in Israel and that this anchoring has deepened through successive Israeli acquisitions (Stoke Talent 2021, AutoDS 2024). Tier B placement is appropriate for frameworks that distinguish structural integration from active occupation-sector participation.
– The V-DIG data-jurisdiction exposure affects buyers and sellers globally who use Fiverr’s platform. Institutional users who are themselves subject to data-governance obligations (GDPR, sector-specific data-residency requirements) should independently assess whether Fiverr’s Israeli-domiciled data processing is compatible with their own regulatory obligations, given the absence of public data-residency disclosures from Fiverr.
For corporate governance and responsible-business engagement:
– The documented Ukraine/Gaza corporate communications asymmetry and the FY2024 20-F’s omission of the ICJ Advisory Opinion and ICC arrest warrants are observable from public filings. Shareholders seeking to raise ESG concerns through formal proxy mechanisms could table a resolution requesting disclosure of the company’s due-diligence framework for operations and data processing in conflict-affected geographies. This recommendation is grounded in the confirmed communications record and regulatory silence, not in speculative harm.
– Resolution of the Lev Echad equipment-procurement evidence gap should be a priority for any organisation considering escalating a Tier B finding to a higher severity. Until primary documentation is reviewed, the V-MIL nil finding should not be superseded.
For researchers and investigators:
– Priority evidence targets in order: (1) Hebrew-language reporting and Lev Echad fundraising records from October–November 2023; (2) live EDGAR retrieval of Fiverr Form 6-K filings from October–December 2023 for operational disclosure; (3) live Who Profits and AFSC Investigate database checks; (4) infrastructure testing or internal disclosure to establish whether any Fiverr workloads traverse the AWS Israel (Tel Aviv) region; (5) FY2024 20-F full-text retrieval and comparison with FY2023.
– The confirmed nil finding for V-MIL should be treated as current-state rather than permanent: Fiverr’s platform capability (AI-matching, enterprise workforce management, global freelance procurement) has theoretical dual-use characteristics that warrant periodic re-examination, particularly as Fiverr Enterprise marketing materials reference “aerospace and defense” as a target vertical. 52
Fiverr F-1 IPO Prospectus (SEC EDGAR) — https://www.sec.gov/Archives/edgar/data/1762301/000104746919003139/a2238508zf-1.htm ↩↩↩↩↩↩↩↩
Fiverr FY2023 Form 20-F (SEC EDGAR) — https://www.sec.gov/Archives/edgar/data/1762301/000117891322000725/zk2227154.htm ↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩
Globes — Fiverr opens Haifa development center — https://en.globes.co.il/en/article-fiverr-opens-haifa-development-center-1001292492 ↩
Calcalist Tech — Kaufman profile and post-Oct 7 statements — https://www.calcalistech.com/ctechnews/article/r1f14fkbn ↩
TechCrunch — Fiverr acquires Stoke Talent — https://techcrunch.com/2022/02/08/fiverr-acquires-stoke-talent-a-platform-for-managing-freelancers/ ↩↩↩↩↩↩↩
Times of Israel — Israeli tech firms halt Russia operations — https://www.timesofisrael.com/israeli-tech-firms-halt-operations-in-russia-over-ukraine-war-as-sanctions-pick-up/ ↩↩
TechCrunch — Fiverr acquires Veed.io — https://techcrunch.com/2023/06/07/fiverr-acquires-veed-io/ ↩↩
Calcalist Tech — Kaufman judicial reform opposition and Oct 7 pivot — https://www.calcalistech.com/ctechnews/article/r1f14fkbn ↩↩↩↩↩↩
AWS Israel (Tel Aviv) Region — https://aws.amazon.com/local/israel/ ↩↩↩↩
Fiverr News / Press Releases — https://www.fiverr.com/news ↩↩
SEC EDGAR — Fiverr Form 6-K filings — https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001762301&type=6-K&dateb=&owner=include&count=40 ↩
Fiverr Q3 2024 Earnings Release — https://investors.fiverr.com/news-releases/news-release-details/fiverr-reports-third-quarter-2024-financial-results ↩
Fiverr — Acquires AutoDS press release — https://investors.fiverr.com/news-releases/news-release-details/fiverr-acquires-autods ↩↩↩↩↩↩
ICJ Advisory Opinion, Legal Consequences Arising from the Policies and Practices of Israel in the Occupied Palestinian Territory — https://www.icj-cij.org/case/186 ↩↩↩↩
ICC — Pre-Trial Chamber I arrest warrants — https://www.icc-cpi.int/news/situation-state-palestine-icc-pre-trial-chamber-i-rejects-state-israel-challenges-admissibility ↩↩↩↩
Fiverr FY2024 Form 20-F — https://s29.q4cdn.com/881027206/files/doc_financials/2024/ar/20-F-2024-for-website.pdf ↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩
Fiverr F-1 IPO Prospectus — https://www.sec.gov/Archives/edgar/data/1762301/000104746919003139/a2238508zf-1.htm ↩↩
NoCamels — Israeli high-tech wartime AI and logistics — https://nocamels.com/2023/10/israeli-high-tech-giants-use-ai-to-streamline-wartime-aid-delivery/ ↩↩↩↩↩↩
UN OHCHR — Database of business enterprises (HRC Res. 31/36) — https://www.ohchr.org/en/hr-bodies/hrc/regular-sessions/session31/database-business-enterprises ↩↩↩
PAX Netherlands — Companies Arming Israel and Their Financiers (June 2024) — https://paxforpeace.nl/publications/companies-arming-israel-and-their-financiers/ ↩↩↩↩
Al-Haq — Business and Human Rights in the Context of Israel’s Genocide in Gaza — https://www.alhaq.org/publications/23289.html ↩↩↩
UN A/HRC/59/23 — Economy of Occupation to Economy of Genocide (Albanese, 2025) — https://documents.un.org/doc/undoc/gen/g25/117/72/pdf/g2511772.pdf ↩↩↩
SIBAT — Israel Defence Export and Defence Cooperation Directorate — https://www.mod.gov.il/English/SIBAT/Pages/default.aspx ↩↩
Fiverr Q1 2024 Earnings Release — https://investors.fiverr.com/news-releases/news-release-details/fiverr-reports-first-quarter-2024-financial-results ↩↩↩↩↩
Fiverr Privacy Policy — https://www.fiverr.com/privacy-policy ↩↩↩↩
AWS Global Infrastructure — Regions and Availability Zones — https://aws.amazon.com/about-aws/global-infrastructure/regions_az/ ↩↩↩
Unleash.ai — Fiverr buys Stoke Talent for $95M — https://www.unleash.ai/hr-technology/freelance-marketplace-fiverr-buys-stoke-for-95m/ ↩↩↩↩
Israeli Privacy Protection Law — Israel Government Portal — https://www.gov.il/en/departments/legalInfo/ppb_regulations ↩
The Guardian — Google and Amazon win $1.2bn Israeli government cloud contract — https://www.theguardian.com/world/2021/apr/22/google-amazon-win-12bn-israeli-government-cloud-contract ↩
No Tech For Apartheid campaign — https://www.notechforapartheid.com/ ↩
Bessemer Venture Partners portfolio — https://www.bvp.com/portfolio ↩↩↩↩
7amleh — Digital Rights of Palestinians annual reports — https://7amleh.org/publications ↩
Calcalist Tech — AutoDS acquisition reporting — https://www.calcalistech.com/ctechnews/article/rjnypqdy0 ↩↩
Israel Innovation Authority — https://innovationisrael.org.il/en/ ↩↩↩↩↩↩
Don’t Buy Into Occupation reports — https://www.dontbuyintooccupation.org/ ↩
Kaufman Twitter/X profile — https://twitter.com/mkaufman ↩↩↩
Fiverr News (corporate communications archive) — https://www.fiverr.com/news ↩↩
OpenSecrets — Fiverr lobbying disclosures — https://www.opensecrets.org/orgs/fiverr-international/lobbying?id=D000077603 ↩↩
LinkedIn — Nir Zohar profile — https://www.linkedin.com/in/nirzohar/ ↩↩
Fiverr — Corporate Governance, Board of Directors — https://investors.fiverr.com/corporate-governance/board-of-directors ↩↩
CyberArk — Board of Directors — https://ir.cyberark.com/corporate-governance/board-of-directors ↩↩
Canadian BDS Coalition — Boycott List of Shame — https://bdscoalition.ca/boycott-list-of-shame/ ↩↩
BDS Movement — Economic action campaigns — https://bdsmovement.net/act/economic-action-campaigns ↩↩
FIDF — Gala events and donor records — https://www.fidf.org/events/gala/ ↩
JNF-USA — Annual reports — https://www.jnf.org/about-jnf/annual-reports ↩
Human Rights Watch — Meta’s Broken Promises: Systemic Censorship of Palestine Content — https://www.hrw.org/report/2023/12/21/metas-broken-promises/systemic-censorship-palestine-content-instagram-and-facebook ↩
7amleh — Digital Rights of Palestinians Report 2023 — https://7amleh.org/2024/02/06/7amleh-launches-the-digital-rights-of-palestinians-report-2023 ↩
Reddit r/Fiverr — Discussion: Fiverr and the Gaza conflict — https://www.reddit.com/r/Fiverr/comments/1md4a54/discussion_fiverr_and_the_gaza_conflict/ ↩
AFSC Investigate — Company database — https://investigate.afsc.org/ ↩
Fiverr Enterprise — https://enterprise.fiverr.com/ ↩
