Military Audit: Booking.com

Direct Defence Contracting & Procurement

No public evidence identified of any contract, tender, framework agreement, or MOU between Booking.com/Booking Holdings and the Israeli Ministry of Defense (IMOD), IDF, Israel Prison Service, Israel Border Police, or other Israeli state security bodies, based on review of SEC filings and NGO investigative databases ¹²³. No public evidence identified of Booking.com appearing in any Israeli defence export directory (e.g., SIBAT), consistent with its status as a demand-side consumer travel platform rather than a goods exporter. No public evidence identified of press releases or trade-press reports describing defence cooperation, joint ventures, or partnership agreements between Booking.com and Israeli defence entities.

Dual-Use Products & Tactical Variants

No public evidence identified of ruggedised, tactical, mil-spec, or defence-grade product variants; Booking.com’s product is a consumer accommodation-booking marketplace with no hardware manufacturing arm. No public evidence identified of any civilian-versus-military product distinction, since no military-specified product exists. No public evidence identified of export licence applications, end-user certificates, or export control reviews connecting Booking.com to Israeli defence or security end-users.

Heavy Machinery, Construction & Infrastructure

No public evidence identified of Booking.com owning, operating, or supplying equipment, vehicles, or machinery used in settlement, barrier, or military-installation construction or demolition. Booking.com’s documented settlement nexus is exclusively as a listings and booking intermediary for existing tourist accommodation, not as a construction or engineering contractor ⁴³. Human Rights Watch’s 2018 investigation, conducted with Kerem Navot, examined 26 Booking.com-listed properties in West Bank settlements and found 16 situated on land Israel designated “state land,” 7 on land under pre-1967 Jordanian administration, 2 on land expropriated for “public use” in Ma’aleh Adumim and Ofra, and 1 of undetermined status, while documenting surrounding Israeli military closed-zone orders and checkpoints restricting Palestinian landowners’ access to that land - findings that describe the surrounding occupation apparatus rather than any Booking.com construction or engineering activity ⁴. No public evidence identified of Booking.com contracts for construction, maintenance, servicing, or expansion of checkpoints, detention facilities, military bases, the separation barrier, or settlement infrastructure.

Supply Chain Integration with Defence Primes

No public evidence identified of any component, sub-system, raw-material, or specialist manufacturing supply relationship between Booking.com and Elbit Systems, Israel Aerospace Industries (IAI), Rafael Advanced Defense Systems, or IMI Systems/Elbit Land. No public evidence identified of specific defence-component categories supplied by Booking.com, consistent with the absence of any identified defence-prime relationship. No public evidence identified of joint development, co-production, technology transfer, or licensed manufacturing agreements between Booking.com and Israeli defence firms.

Logistical Sustainment & Base Services

No public evidence identified of Booking.com service contracts - catering, transport, fuel, waste management, facilities maintenance, or telecoms - supplied to IDF bases, training facilities, detention centres, or security installations. Booking.com’s Golan Heights and West Bank/East Jerusalem settlement listings are separately documented in NGO databases ³⁵, and open-source reporting independently notes active IDF installations in the Golan Heights region; however, no source reviewed links Booking.com commercially or operationally to these installations, and the geographic proximity of tourist listings and military installations in the same region does not by itself constitute evidence of a service relationship. No public evidence identified of Booking.com shipping, freight-forwarding, or port-handling contracts servicing Israeli defence logistics or military cargo, consistent with a business model involving no physical freight operations.

Munitions, Weapons Systems & Strategic Platforms

No public evidence identified of any role, direct or indirect, in the manufacture, integration, or supply of small arms, artillery, armoured vehicles, drones, naval vessels, ammunition, explosive ordnance, chemical propellants, or warhead components to Israeli end-users. No public evidence identified of any role in Iron Dome, David’s Sling, Arrow missile defence, fighter aircraft, main battle tank, warship, or ballistic missile programmes. No public evidence identified of guidance electronics, fire-control systems, radar components, propulsion units, or warhead-casing supply attributable to Booking.com.

Export Licensing, Regulatory & Legal History

No public evidence identified of any export licence grant, denial, suspension, or revocation decision in any jurisdiction concerning Booking.com and Israeli military or security end-users, consistent with Booking.com exporting no controlled goods. No public evidence identified of arms-embargo or export-control enforcement actions against Booking.com. Separately, a documented legal-proceedings track exists on a financial-crime and settlement-nexus basis, unrelated to arms export: on 8 November 2023 the European Legal Support Center (ELSC), Al-Haq, SOMO and The Rights Forum filed a criminal complaint with the Dutch Public Prosecution Service alleging Booking.com introduces proceeds of settlement-related activity into the Dutch financial system in violation of Dutch anti-money-laundering law ⁶⁷. In May 2024 the Dutch Public Prosecutor indicated intent to investigate the complaint ⁸⁹. On 18 December 2024 the complainant coalition submitted additional evidence to the Rotterdam Public Prosecutor’s Office ¹⁰. The coalition subsequently challenged the prosecutor’s prolonged inaction before the Dutch Court of Appeal ¹¹¹²¹³. This proceeding concerns alleged money laundering tied to settlement-listing revenue rather than any arms-embargo or defence-export enforcement matter ^6789111312.

Civil Society Scrutiny & Documented Investigations

Booking.com is named in the UN OHCHR database of businesses involved in Israeli settlements, first published in February 2020 and updated in subsequent iterations ¹⁴¹⁵¹⁶. UN Special Rapporteur Francesca Albanese’s report “From economy of occupation to economy of genocide” (A/HRC/59/23, presented 3 July 2025) states Booking.com’s West Bank settlement listings more than doubled since 2018 and its East Jerusalem listings tripled following October 2023, reaching 70 settlement properties, and characterises this activity as part of “colonial profiteering” ¹⁷¹⁸¹⁹. Human Rights Watch’s “Bed and Breakfast on Stolen Land” (20 November 2018), produced with Kerem Navot, documented 26 Booking.com properties in West Bank settlements and the disputed land status underlying them ⁴. Amnesty International (30 January 2019) named Booking.com and Airbnb as tourism companies “driving settlement expansion, profiting from war crimes” ²⁰. Who Profits (data validity 30 November 2024) documents 24 Booking.com listings across 12 West Bank settlements, 7 in East Jerusalem settlement neighbourhoods, and 152 listings across 28 settlements in the occupied Syrian Golan, classifying the company under “Settlement Enterprise / Services to the Settlements” and “Tourism sector” ³. AFSC Investigate cites 19 West Bank/East Jerusalem listings and 25 Golan Heights listings as of 2022, documents the role of Booking.com’s Israeli subsidiary in providing training, promotion and verification support to settlement hosts, and quotes HRW’s assessment that “Booking.com cannot remediate these harms, because they are inherent to the settlement enterprise” ². A Guardian investigation conducted jointly on Airbnb and Booking.com (30 August 2024 dataset) identified 26 Booking.com hotels across the West Bank including East Jerusalem ⁵. An Eko/SumOfUs shareholder report published ahead of the Booking Holdings 2025 AGM cites 41 active properties across 14 West Bank settlements, with East Jerusalem listings rising from 13 to 39 between 9 November 2023 and 9 November 2024 ²¹²². The Don’t Buy Into Occupation 2025 inventory, reported via DutchNews in November 2025, confirms Booking.com remains active in West Bank settlements ²³. Additional civil-society and press coverage of the settlement-listings controversy includes JusticeInfo.net ²⁴, Follow the Money ²⁵, Business & Human Rights Resource Centre ^2627287, The New Arab ²⁹, and Middle East Eye ³⁰²⁸. Employee-facing developments include reporting of an internal employee petition campaign against settlement listings ³¹. In the opposite direction, Israel’s Tourism Minister publicly called on Booking.com’s CEO to cancel a 2018 decision to relabel West Bank/“Judea and Samaria” listings ³². Booking.com’s corporate response has included relabeling some listings in 2018 and adding a safety/human-rights-risk warning to West Bank listings in September 2022, reported by Al Jazeera and Business & Human Rights Resource Centre, with rights groups characterising the move as insufficient ³³²⁷. In 2026 proxy-statement materials, JLens Network argues against a shareholder resolution on Booking.com’s Israeli settlement operations, citing the company’s position that the settlement-related business is “financially insignificant” and that shareholder-resolution allegations are “broad and unsubstantiated” ²¹. Boycott and divestment campaigns targeting Booking.com over settlement-tourism revenue include the BDS Movement’s “Booking.com: Stop Profiting from War Crimes” ³⁴ and SumOfUs/Eko’s “Stop Booking Apartheid” ³⁰; no campaign identified frames Booking.com’s conduct as defence-sector activity specifically.

End Notes