Booking.com

Key Findings

• Economic: Booking.com continues to intermediate accommodation listings in Israeli settlements in the West Bank, East Jerusalem, and the occupied Syrian Golan; Who Profits documented 24 West Bank listings, 7 East Jerusalem listings, and 152 listings across 28 Golan settlements in data valid through November 2024.¹
• Political: The company’s listing and warning-label policies have remained contested: it relabelled some locations in 2018 and introduced a revised 2022 travel-risk notice, while continuing the listings and defending its approach as consistent worldwide.²
• Digital: Booking.com has a Tel Aviv R&D presence developed after acquisitions of Israeli firms Qlika and Evature; its stated work concerns consumer-travel AI and marketplace technologies, not Israeli state or security systems.³
• Not found: No public evidence identified of Booking.com defence contracts, military product lines, military logistics, participation in Project Nimbus, or provision of technology to Israeli military, intelligence, or security bodies.⁴

Target Profile

Key Facts:

• Booking.com Israel Online Hotel Reservations Ltd. is registered in Tel Aviv-Yafo under number 514762970.⁹
• Priceline Group acquired Israeli ad-tech firm Qlika in 2014; Booking.com acquired Tel Aviv-based Evature in September 2017.³
• Booking Holdings reported Israel represented approximately 1% of global room nights on a booker-plus-inbound basis in its February 2024 Q4 2023 earnings call.¹⁰

Executive Summary

Booking.com is a consumer travel marketplace operated within the Booking Holdings group. Its documented Israel/Palestine nexus centres on an Israeli operating subsidiary, a Tel Aviv R&D office, and the platform’s commercial intermediation of accommodation listings in Israeli settlements in the occupied West Bank, including East Jerusalem, and in the occupied Syrian Golan Heights.^{1, 3, 9} The company’s platform role is distinct from owning, constructing, or operating the listed properties: Booking.com told Human Rights Watch that it does not buy or sell rooms and functions as a booking platform.⁶

The principal evidence record concerns settlement-tourism activity. Human Rights Watch and Kerem Navot documented 26 Booking.com-listed properties in West Bank settlements in 2018 and examined the land status of 25 of them.⁶ Later datasets vary by methodology and date, but report continued and, in some accounts, increased settlement listings. Who Profits documented 24 listings across 12 West Bank settlements, seven East Jerusalem properties, and 152 listings in 28 settlements in the occupied Syrian Golan as of data valid through November 2024.¹ The OHCHR business-and-human-rights database has listed Booking.com/Booking Holdings in connection with Israeli settlement activity since 2020, including in later updates.¹¹

The company has made limited policy changes without withdrawing from the relevant market. It changed some location labels in 2018 from “Israel” to “Palestinian Territory, Israeli Settlement.”² In 2022 it announced a risk warning for relevant areas, later revising the wording to direct users to government travel advisories for areas that may be conflict-affected.² Booking.com’s stated position is that its approach is globally consistent, that it adds information so travellers may make informed choices, and that it complies with Dutch and US law; it says no applicable law prohibits listing West Bank settlement accommodation.^{8, 12}

The allegations underpinning ongoing legal proceedings remain allegations, not findings of liability. A coalition of SOMO, ELSC, The Rights Forum, and Al-Haq filed a Dutch criminal complaint in November 2023 alleging settlement-rental revenue constituted laundering of proceeds of war crimes. The Dutch Public Prosecutor indicated an intention to investigate in May 2024; reporting through April 2026 describes an unresolved matter and an Article 12 procedure seeking action after alleged prosecutorial delay.¹² A French complaint filed in October 2025 is likewise unresolved.¹³

No public evidence identified supports attributing Israeli military contracting, weapons production, military logistics, security-agency technology provision, Project Nimbus participation, data-centre operations in Israel, or Israeli state financing to Booking.com.^{4, 14} The final human-vetted V6.5 result is therefore driven by the documented settlement-listing and operational nexus rather than a military nexus: BRS 626, Tier B (Severe Complicity).

Timeline of Relevant Events

Corporate Overview

Booking.com is a Netherlands-domiciled subsidiary of Booking Holdings Inc., a Delaware-incorporated, NASDAQ-listed public company headquartered in Norwalk, Connecticut.⁵ The company’s documented business model is an online accommodation and travel-booking intermediary rather than a retailer, manufacturer, construction contractor, or physical-goods supplier.¹⁶

The confirmed Israeli corporate presence is Booking.com Israel Online Hotel Reservations Ltd., registered in Tel Aviv-Yafo. The audit identifies the subsidiary as supporting a Tel Aviv engineering, machine-learning, and AI R&D operation, including work on recommendation systems, computer vision, natural-language understanding, reinforcement learning, marketplace algorithms, and voice interaction for Booking.com’s consumer platform.^{3, 9} Public reporting identified a later office location in the Azrieli Sarona tower; specific current headcount was not identified in the audits.³

The corpus does not establish an Israeli parent company, Israeli state ownership, an Israeli governmental board appointment, a formal Israeli state partnership, or an Israeli headquarters.^{5, 16} Booking.com’s settlement nexus arises from listings sourced from property operators, including settlement-based operators, and from local staff support described by AFSC Investigate as training, promotional advice, and listing-verification activity.¹⁷

Domain Summaries

Military: Military

Mechanism of Involvement

No public evidence identified of contracts, tenders, framework agreements, MOUs, or other procurement relationships between Booking.com/Booking Holdings and the Israeli Ministry of Defense, IDF, Israel Prison Service, Border Police, or other Israeli security bodies.⁴ No public evidence identified of military products, tactical variants, export licences, dual-use goods, weapons systems, defence-prime supply relationships, military freight, base services, construction work, or infrastructure work attributable to Booking.com.⁴

The documented settlement nexus is limited to a travel-platform role for existing accommodation listings. Human Rights Watch’s land-status and access findings describe the setting of listed settlement properties and surrounding occupation infrastructure; they do not establish Booking.com construction, engineering, checkpoint, barrier, or military-installation activity.⁶

Counter-Arguments and Evidence Limits

Booking.com’s product is a consumer accommodation-booking marketplace, without an identified hardware-manufacturing or military-services arm.⁴ Listings in regions that also contain military installations do not, without a demonstrated commercial or operational link, establish military support. No public evidence identified connects Booking.com’s settlement listings to services for IDF installations or to defence logistics.⁴

The Dutch legal proceeding concerns alleged financial proceeds from settlement-listing activity, not arms exports, military contracting, or sanctions enforcement. It remains unresolved.¹²

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

Booking.com has a documented Israeli R&D footprint. It acquired Evature in 2017 and then announced a Tel Aviv AI-focused innovation centre; its publicly stated work includes consumer-facing recommendation systems, computer vision, natural-language understanding, reinforcement learning, marketplace algorithms, and voice interaction.³ The audit also identifies AWS as Booking.com’s disclosed cloud and infrastructure provider, including public AWS case studies involving Booking.com workloads.¹⁸

No public evidence identified indicates that Booking.com operates or leases data-hosting infrastructure in Israel. The Tel Aviv operation is documented as an engineering and innovation office rather than a data centre.¹⁴ AWS is separately documented as a Project Nimbus contractor to the Israeli government, but no source reviewed establishes that Booking.com’s AWS workloads use Nimbus-designated infrastructure or that Booking.com participates in Project Nimbus.¹⁴

Counter-Arguments and Evidence Limits

No public evidence identified of Booking.com using Israeli biometric, predictive-policing, surveillance, social-media-monitoring, or workforce-surveillance products.¹⁴ No public evidence identified supports a contract or partnership between Booking.com and Israeli military, intelligence, police, or security agencies, nor evidence that its consumer AI models are supplied to or repurposed by such entities.¹⁴

The AWS/Nimbus connection is vendor-level only. An infrastructure vendor’s separate government contract does not establish a customer’s participation in that programme absent evidence connecting the customer’s workloads to it.¹⁴

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

The central economic nexus is Booking.com’s intermediation of accommodation listings in settlements. Human Rights Watch and Kerem Navot identified 26 listed West Bank settlement properties in 2018, determining land status for 25 and reporting that two were then labelled as within Israel.⁶ Who Profits’ data valid through November 2024 recorded 24 listings across 12 West Bank settlements, seven East Jerusalem properties, and 152 listings across 28 settlements in the occupied Syrian Golan.¹

The audit also documents direct operational activity in Israel through the Tel Aviv subsidiary and R&D centre. Israel-based personnel are reported to communicate directly with accommodation providers, including settlement operators, and to offer training, promotional advice, and listing-verification support.^{9, 17} Booking Holdings stated that Israel represented approximately 1% of global room nights on a booker-plus-inbound basis in its Q4 2023 earnings call.¹⁰

Counter-Arguments and Evidence Limits

Booking.com does not own, buy, sell, construct, or operate the accommodation properties identified in the audit; it describes itself as a booking platform.⁶ It is not a goods retailer or importer, and no public evidence identified supports Israeli agricultural sourcing, physical-goods procurement, Israeli sovereign-bond holdings, Israel Bonds holdings, or Israel-focused fund positions attributable to Booking Holdings.¹⁶

Listing totals differ across sources and periods because the audits cite different dates, geographic scopes, and methodologies. They should not be combined into a single cumulative count. The inference that value from the Israeli subsidiary flows to foreign parent entities follows the documented group structure, but no explicit Israel-specific profit-repatriation disclosure was identified.^{9, 16}

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

Booking.com’s operational and communications choices regarding settlement listings form the principal Political record. The company changed some location labels in 2018 and adopted a revised travel-advisory warning in 2022, while maintaining the listings.² In employee-facing remarks, CEO Glenn Fogel said Booking had “never said we won’t do business somewhere because we disagree” and that it should not dictate destinations; the company has described its approach as globally consistent and based on adding information for traveller choice.⁸

The company and its parent are named in the OHCHR database of enterprises linked to settlement activity.¹¹ In its FY2026 proxy material, the Booking Holdings board recommended voting against a shareholder proposal requesting reporting on oversight of settlement-related human-rights risks. The board described the settlement-linked business as not material and described the underlying allegations as broad and unsubstantiated.⁸

The Dutch and French complaints create a material accountability context but are unresolved allegations. The Dutch complaint alleges laundering of settlement-rental proceeds; the prosecutor indicated an intention to investigate, and complainants later sought a court order following alleged inaction. The French complaint alleges complicity in aggravated concealment of war crimes and facilitation of occupation tourism.^{12, 13}

Counter-Arguments and Evidence Limits

Booking.com’s strongest documented defence is that it fully complies with Dutch and US law, does not agree with allegations of illegality, and considers there to be no applicable law prohibiting West Bank settlement accommodation listings.¹² It also frames its role as neutral travel facilitation rather than political direction, arguing that travellers should make their own decisions with additional information provided on-platform.⁸

No public evidence identified of Booking Holdings lobbying specifically on anti-BDS laws, Israel trade policy, settlement-trade rules, or of corporate donations to FIDF, JNF/KKL, reservist funds, settlement-support organisations, or Israeli state/military initiatives.¹⁹ CEO Fogel’s UJA-Federation recognition listing is not itemised by cause and does not establish an Israel-specific, military, or settlement-related donation.²⁰

The contrast drawn by critics between Booking’s suspension of services in Russia and Belarus after Russia’s 2022 invasion of Ukraine and its continuing settlement listings is a critique of corporate consistency, not proof of a state partnership or military relationship.²¹

Named Entities and Evidence Map

BDS-1000 Score

Method: V6.5

• V_MAX: 7.00 Avg_OTHERS: 2.58
• BRS Score: 626 Tier: B (Severe Complicity)

V_MAX is driven by the documented economic role of settlement listings and local operational support, with the political score reflecting continued listings, disputed labelling and warning policies, corporate posture, and unresolved legal scrutiny. The lower digital result reflects the Israeli R&D footprint rather than evidence of security-sector technology provision; Military is zero because the audit identified no military nexus.

The V6.5 method is scale-free, evidence-only, and human-vetted. Scores reflect documented activity type (I), operational scale (M), and directness (P), rather than unverified allegations, transitive associations, or unsupported inference.

Methodology Note

• Evidence is limited to the four supplied domain audits and their cited documentary record.
• Scores are evidence-only and scale-free: I addresses activity type, M scale, and P directness.
• “No public evidence identified” is used where the audits’ targeted checks found no substantiating public record; it is not a claim that no such activity could ever exist.
• Divested, exited, or discontinued operations are mitigating context and are not treated as continuing conduct without evidence.
• Entity attribution is direct: a vendor’s separate activity, an investor’s portfolio, geographic proximity, or an executive’s non-itemised charitable recognition does not by itself establish company complicity.
• Settlement operations may bear both Economic and Political relevance because they combine commercial intermediation with policy, governance, and territorial-labelling choices; this does not convert them into military activity.