Booking.com - Political Audit

Corporate Communications & Public Stance

In December 2023, CEO Glenn Fogel told Bloomberg that hotel and flight bookings had “come back” in the weeks following the 7 October 2023 Hamas attack, without offering any statement of moral concern regarding Palestinian civilian harm ¹. In later remarks addressing internal employee pressure over West Bank listings, Fogel stated the company’s mission is “to make it easier for everyone to experience the world” and that Booking has “never said we won’t do business somewhere because we disagree,” adding that the company should not “dictate where people can and cannot travel” ²³. The company’s standard public response to settlement-listing controversy is that its “approach is consistent worldwide” and that in conflict areas it “add[s] information to our platform so travelers can make an informed choice” ².

This posture contrasts with Booking Holdings’ response to Russia’s February 2022 invasion of Ukraine, when the company said it was “deeply concerned about the devastating events unfolding in Ukraine,” made employee safety its “top priority,” and suspended booking services in Russia and Belarus citing compliance with “all applicable global sanctions” ⁴⁵⁶. Booking Holdings’ FY2022 proxy statement explicitly condemned “the senseless violence and wanton disregard for the lives of the Ukrainian people as a result of the Russian invasion” ⁷. Separately, Booking paid Russia $16.7 million in 2021 over a competition-law breach, indicating an active regulatory-compliance posture toward the Russian market prior to the invasion ⁸. Commentary from Electronic Intifada has explicitly framed the gap between Booking’s Russia suspension and its continued Israeli-settlement listings as a double standard ⁹. In its FY2026 shareholder-proposal opposition statement, the Booking Holdings board characterized West Bank/settlement-linked listings as “not material to the Company’s business” ¹⁰¹¹.

No public evidence identified of a corporate statement specifically addressing the humanitarian toll of the Gaza war, the July 2024 ICJ Advisory Opinion, or the November 2024 ICC arrest warrants.

Operations in Occupied or Contested Territories

Who Profits documented Booking.com listings across at least 19 illegal West Bank settlements (including East Jerusalem) as of a 2022 dataset current to 30 November 2024 ¹². AFSC Investigate’s tracker separately recorded 24 listings across 12 West Bank settlements - including Ma’ale Adumim, Geva Binyamin, Neve Daniel, and Giva’at Ze’ev - plus seven East Jerusalem listings in Pisgat Ze’ev and Ramat Shlomo, with the Pisgat Ze’ev listings mislabeled as located in “Israel” ¹³. The New Arab separately reported a Palestinian family’s allegation of illegal land use tied to a Booking.com-listed property ¹⁴. In the occupied Syrian Golan Heights, Who Profits identified 25 illegal settlements and AFSC Investigate recorded 152 listings across 28 settlements - including Katzrin, Ein Zivan, and Hamat Gader - all categorized on-platform as Israeli locations ¹³.

A February 2025 Guardian investigation, as summarized by Divest Herts, identified 402 total settlement listings across Airbnb and Booking.com in the West Bank and East Jerusalem, with 52 attributed to Booking.com covering roughly 760 rooms and capacity for over 2,000 guests ¹⁵¹⁴. Human Rights Watch’s 2018 report with Kerem Navot, “Bed and Breakfast on Stolen Land,” found at least 15 Booking.com settlement listings sited on land Israel designated as “state land” or acknowledged as privately owned by Palestinians ¹⁶; HRW’s companion release the same day announced that Airbnb would end settlement rentals, a step Booking.com did not mirror ¹⁷. Reporting indicates the number of Booking.com listings in occupied territory has continued rather than declined since the October 2023 war began ²¹⁵.

Both Booking.com B.V. and parent Booking Holdings Inc. appear in the UN OHCHR database of business enterprises linked to Israeli settlement activity maintained under Human Rights Council Resolution 31/36; Booking Holdings was named among 17 parent companies in a 30 June 2023 update as one of only seven not headquartered in Israel ¹⁸. The database’s original February 2020 release listed 112 entities ¹⁹²⁰, and further updates tied to 2025 reporting reportedly brought the total to 158 names ¹⁵. UN Special Rapporteur Francesca Albanese’s June/July 2025 report “From economy of occupation to economy of genocide” (A/HRC/59/23) addressed corporate involvement in the settlement economy, with related Middle East Eye coverage noting Airbnb and Expedia among firms tied to West Bank settlements ^21222324.

Regulatory and legal scrutiny has intensified in two jurisdictions. In the Netherlands, SOMO, the European Legal Support Centre, The Rights Forum, and Al-Haq filed a criminal complaint on 8 November 2023 accusing Booking.com of laundering revenue from settlement rentals under Dutch anti-money-laundering law and Article 1(4) of the Dutch International Crimes Act ^25262728. The Dutch Public Prosecutor indicated in May 2024 that it would investigate ²⁹, but as of reporting through 2026 had not reached a decision, prompting the coalition to file a complaint with the Dutch Court of Appeal on 8 April 2026 over the delay ³⁰³¹. Booking.com has stated it “does not agree with allegations of illegal activities,” maintains it “fully complies with Dutch and American laws,” and asserts “there are no applicable laws that prohibit listing accommodations in Israeli settlements in the West Bank,” a position it reiterated on 23 May 2024 ¹⁴¹⁰. In France, the Ligue des droits de l’Homme filed a legal complaint in October 2025 against Airbnb and Booking.com alleging complicity in “aggravated concealment of war crimes” and facilitation of “occupation tourism,” with attorney Patrick Baudouin alleging the platforms “enable and facilitate, both directly and indirectly, the creation and expansion of Israeli settlements” ³²³³³⁴.

Third-party divestment activity reflects continued external scrutiny rather than company action: the University of Manchester divested £10 million (including Booking.com holdings) in August 2020, and Fresno State and San Francisco State student governments passed divestment resolutions naming Booking.com the same year ¹³. By contrast, Harvard Management Company reinvested $150 million in Booking Holdings as of January 2025, having previously held roughly $200 million across UN-listed settlement-tied companies as of March 2020 reporting ³⁵³⁶.

Internal Governance, Content & Retail Policies

Internal employee dissent over West Bank settlement listings dates to 2018 and escalated after 7 October 2023 ³. Petitions calling on Booking.com to cease settlement listings recurred multiple times, including an earlier petition with roughly 300 signatures and a further petition distributed 12 September 2025 that drew over 220 signatures ²³. In 2021, Booking’s compliance function removed an internal petition post from the company’s “Blink” intranet forum, citing prevention of “divisive and politically charged discussion” ²³. Two weeks into the October 2023 war, management emailed staff asking that non-work-related messages be kept “to a minimum” ²³. A worker collective, “B.Workers for Palestine,” formed around what it terms internal repression of Palestine solidarity at the company, coinciding with the external “Stop Booking Apartheid” campaign ³⁷. That campaign organized public pressure through an online petition ³⁸, while NGO Monitor characterized it as part of a coordinated “NGO BDS Network” effort targeting the company ³⁹. Reporting explicitly notes no documented formal disciplinary action (termination or demotion) against named employees over pro-Palestinian speech, distinct from the 2021 informal content takedown ²³.

On platform labeling policy, Booking.com in September 2022 initially planned a warning label flagging “increased risk to safety and human rights or other risks to the local community and visitors” for settlement listings, then revised the wording on 2 October 2022 to direct users to “review their government’s travel advisories before booking in the area, which may be conflict-affected,” removing explicit “occupied” framing ⁴⁰. Israel’s Foreign Ministry welcomed the revision as the product of “discreet and effective dialogue,” and then-Prime Minister Yair Lapid credited it with countering “false anti-Israel propaganda” ⁴⁰. Al-Haq welcomed the original safety-warning step as an important first move while urging full disengagement ⁴¹, and the Business & Human Rights Resource Centre reported rights groups calling the final, softened warning insufficient ⁴². Separately, Booking.com changed some listing location labels from “Israel” to “Palestinian Territory, Israeli Settlement” in 2018, but AFSC Investigate’s 2024 data snapshot found some East Jerusalem listings still mislabeled as “Israel,” indicating inconsistent implementation ¹³. On enforcement in the opposite direction, Booking.com removed two guesthouses (in Naples, Italy and Bosnia) in 2023–2024 after they refused Israeli guests, citing a contractual “unequivocal commitment to prevent in any way discrimination,” and covered alternative accommodation costs for the affected Israeli traveler ⁴³.

No public evidence identified of independent academic studies or regulatory inquiries into Booking.com’s algorithmic content moderation specific to Israel-Palestine material, as distinct from the documented listing/location-labeling disputes. On retail and supply-chain practices, Booking.com is a booking-services platform rather than a retail goods company; No public evidence identified of product-sourcing or labeling regulatory actions against it, with the platform’s geographic listing-categorization practices serving as the closest analogue and being addressed above.

Brand Heritage & State Partnerships

No public evidence identified of Booking.com or Booking Holdings using military heritage, defense-sector ties, or state-security origins in its commercial branding; the company’s founding narrative traces to Amsterdam travel-technology origins in 1996 with no defense linkage surfaced in any source reviewed. No public evidence identified of a formal “Brand Israel”-style state marketing partnership between Booking.com and the Israeli Ministry of Tourism.

Booking.com operates a Tel Aviv research-and-development office, relocated to the Azrieli Sarona complex, working on recommendation systems, computer vision, natural-language understanding, and reinforcement learning ⁴⁴⁴⁵. A single secondary source characterizes the Tel Aviv office as “gaining influence, giving pro-Israeli employees a more prominent role within the company”; this claim is unverified against a primary source and is noted here only as an unconfirmed lead. No public evidence identified of Booking.com or Booking Holdings hosting Israeli government officials, accepting Israeli state honors, or holding formal academic or governmental institutional partnerships in Israel.

Lobbying, Advocacy, Financing & Logistics

Booking Holdings spent $2,745,000 on federal lobbying in 2025 per OpenSecrets records ⁴⁶, which also maintain the company’s full lobbyist- and bill-level disclosure history ⁴⁷. No public evidence identified of Booking Holdings lobbying specifically on anti-BDS legislation, Israel trade policy, or settlement-related trade rules within the sources reviewed. No public evidence identified of a Booking Holdings corporate PAC contribution tied specifically to Israel-Palestine policy. No public evidence identified of corporate donations by Booking.com or Booking Holdings to FIDF, JNF/KKL, Lev Echad, Israeli reservist funds, or settlement-support organizations, despite targeted checks of donor-recognition pages for these bodies. No public evidence identified of Booking.com directing free services, logistics, or infrastructure to Israeli state, military, or state-aligned NGO efforts during the current conflict.

At the executive level, CEO Glenn Fogel appears on the UJA-Federation of New York’s “Tzedek Society Roll of Honor,” a Jewish-communal major-donor recognition listing that is not itemized by cause and covers a broad range of UJA-Federation programming beyond Israel-specific activity ⁴⁸. No public evidence identified tying this listing specifically to IDF, FIDF, JNF, or settlement organizations; it is flagged as a lead requiring primary-source verification rather than a confirmed financing link.

Corporate Structure & Primary Mission

Booking Holdings Inc. is a Delaware-incorporated, NASDAQ-listed (BKNG) public company headquartered in Norwalk, Connecticut; Booking.com B.V., the entity named in the Dutch criminal complaint, is a wholly owned, Netherlands-domiciled subsidiary ¹³²⁵. No public evidence identified of any state-held golden share, sovereign equity stake, or founding corporate mandate tying Booking Holdings’ charter to advancing any state’s geopolitical goals. The company’s stated mission, per CEO Fogel, is commercial and travel-facilitation oriented - “to make it easier for everyone to experience the world” - rather than a state-security or geopolitical mandate ²³. Consistent with this framing, the Booking Holdings board’s FY2026 proxy statement positions settlement-linked listings as “not material to the Company’s business,” i.e., incidental to rather than central to its commercial operations ¹⁰¹¹.

Executive & Leadership Footprint

Beyond the UJA-Federation Tzedek Society listing for CEO Glenn Fogel ⁴⁸, No public evidence identified of Fogel or other named Booking Holdings executives or board members making personal donations to FIDF, JNF, Lev Echad, or settlement organizations, or holding equity in Israeli defense, surveillance, or cyber firms. Fogel’s only identified public remarks on Israel-Palestine are his December 2023 comments to Bloomberg on post-7 October travel demand recovery ¹ and his internal, employee-facing remarks defending continued settlement listings and opposing the company “dictat[ing]” travel destinations ²³; no op-eds, signed letters, or social-media advocacy statements by Fogel or other named executives on Israel-Palestine were identified. No public evidence identified of individual Booking Holdings board members holding seats in pro-Israel advocacy organizations (e.g., CFI, AIPAC, ADL, USISTF) or settlement-linked organizations; board-member-by-member biographical detail from the FY2026 proxy filings was not fully extracted in the underlying research and is flagged as an evidence gap ¹¹⁴⁹.

For the FY2026 annual meeting (2 June 2026), Proposal 6 - filed by Rewan Al-Haddad of Ekō on behalf of the Lea Langdon Revocable Trust - requested that the board disclose a report on its oversight of human-rights risks connected to Israeli settlements in the Occupied Palestinian Territory ¹⁰. The Booking Holdings board recommended shareholders vote AGAINST the proposal, characterizing the settlement-linked business as “not material” and the underlying Dutch criminal allegations as “broad and unsubstantiated” in a company statement dated 23 May 2024 cited in the proxy ¹⁰¹¹. JLens, a Jewish-values-aligned investment advocacy network, also urged an AGAINST vote, describing the proposal as “the latest installment in a multi-year, Boycott, Divestment, and Sanctions (BDS)-linked campaign targeting the Company” - implying prior-year proposals whose specific text and outcomes were not located in this review ¹⁰⁵⁰. No public evidence identified of the final vote outcome, as the meeting date postdates the available reporting.

End Notes