Booking Holdings

Key Findings

• Settlements: Investigations documented Booking.com accommodation listings in Israeli settlements over multiple reporting periods. In May 2026, Ekō identified 41 listings across 14 settlements in the occupied West Bank, including East Jerusalem; this was an investigated sample, not an exhaustive inventory.^{1, 2}
• Digital: Booking.com publicly identifies a Tel Aviv Machine Learning Centre and engineering operation. The group also acquired Israeli commercial technology companies Qlika and Evature; the current standalone deployment of their original software is unknown.^{3, 4, 5}
• Political: Booking Holdings’ board opposed a 2026 shareholder proposal seeking additional reporting on settlement-related human-rights risks, arguing that existing oversight and reporting were sufficient. Shareholders rejected the proposal on 2 June 2026.^{6, 7}
• Not found: No public evidence identified of Israeli military procurement, weapons supply, military logistics or purpose-built targeting systems attributable to Booking Holdings. The documented business is civilian travel intermediation and commercial technology development.^{8, 9, 3}

Target Profile

Executive Summary

Booking Holdings operates civilian online travel and reservation businesses, principally through Booking.com, Priceline, Agoda, KAYAK and OpenTable. Its strongest documented Israel/Palestine nexus is Booking.com’s commercial relationship with accommodation providers in Israeli settlements. Human Rights Watch and Amnesty International documented listings and provider-support activities in 2018–2019; subsequent investigations documented settlement accommodation in later periods, including 2026. These findings concern promotion and reservation intermediation, rather than ownership of the accommodation properties.^{8, 9, 14, 1, 2}

The economic record combines repeated listing observations with property-specific investigation. The Guardian identified 52 Booking.com settlement listings in an August 2024 dataset published in February 2025. Ekō’s May 2026 investigation identified 41 listings across 14 settlements and examined a Neve Daniel property associated with the Al-Sbeih family’s documented ownership claim. These datasets differ in date, coverage and method and cannot be treated as a continuous inventory. Advertised prices and guest reviews demonstrate commercial offers and historical guest activity, but do not establish realised revenues or Booking.com’s settlement-specific commissions.^{15, 1, 2}

The digital nexus includes an active, company-described Tel Aviv Machine Learning Centre, engineering teams and historical acquisitions of Israeli commercial technology companies. Qlika was acquired in 2014 and integrated into Agoda; Booking.com acquired Evature in 2017. Corporate disclosures establish continuing Qlika-linked management and personnel, while Booking.com identifies research in recommendation systems, computer vision, natural-language understanding and reinforcement learning. No public evidence identified that these activities supply Israeli military or intelligence systems. Israeli access to identifiable production customer records, Israeli hosting volumes and current standalone use of the acquired companies’ original software remain unestablished.^{3, 4, 5, 12, 16}

The political record concerns decisions over settlement listings, disclosure and internal governance. Booking Holdings defends a global policy of allowing listings unless applicable law prohibits them, providing destination information and conducting enhanced due diligence. Employee objections, the board’s opposition to additional settlement-risk reporting and the failed June 2026 shareholder proposal document management and shareholder engagement with the issue. Dutch complainants allege money laundering involving settlement-booking proceeds; the April 2026 Article 12 procedure sought review of prosecutorial inaction and did not establish criminal liability.^{6, 17, 18, 7, 19}

The fixed, human-vetted V6.6 result is BRS 658, Tier B (Severe Complicity). Its evidentiary basis lies in settlement-related economic activity, civilian digital operations and documented governance decisions. Military remains 0.00: no public evidence identified of qualifying military contracting, weapons, defence components or military sustainment. The classification is a corpus assessment, not a judicial finding.

Timeline of Relevant Events

Corporate Overview

Booking Holdings is the US parent of a travel-platform group. Its December 2025 subsidiary exhibit identifies Booking.com B.V., Agoda Company Pte. Ltd., KAYAK Software Corporation, OpenTable Inc. and Priceline-related entities as wholly owned subsidiaries. The exhibit expressly omits some individually insignificant subsidiaries and therefore is not a complete local-entity register.^{8, 28}

Booking.com B.V. is registered and based in Amsterdam. Its legal disclosures identify it as the online reservation-service operator and distinguish local support companies from the entity providing the booking platform. Booking.com’s offices directory separately identifies Booking.com Israel Online Hotel Reservations Ltd. Amnesty’s 2019 investigation described a wholly owned Israeli support subsidiary communicating with accommodation operators, including settlement providers, about listing information and promotion. Continuation of each historical interaction is unknown.^{29, 13, 14}

The Israeli technology operation extends beyond accommodation-provider support. Booking.com identifies its Tel Aviv office as home to a Machine Learning Centre and engineering teams. Its page states that the current office opened in 2021 and displays 70 employees; this is a company-published representation, not an independently audited headcount at the research cut-off.³

Qlika’s acquisition belongs to Agoda’s corporate history; Evature’s acquisition belongs to Booking.com’s. The digital audit and supplemental economic findings establish these transactions and correct earlier economic-audit statements suggesting that no additional acquisitions or dedicated Israeli research operation had been identified. Neither historical acquisition establishes a military relationship. No public evidence identified that Agoda, Priceline, KAYAK or OpenTable independently maintained the specific settlement listings documented on Booking.com.^{3, 4, 5, 12}

Domain Summaries

Military: Military

Mechanism of Involvement

No qualifying military mechanism was established. The reviewed corporate filings describe accommodation, transport, restaurant and related reservation services. Settlement investigations document civilian tourism intermediation, including listings, promotion and provider support; they do not identify military procurement or construction contracts.^{8, 9, 14}

Across the military audit, No public evidence identified of contracts with the Israeli Ministry of Defence, IDF or other reviewed security organisations; weapons or ammunition supply; defence-prime components; military-base services; military freight; controlled military exports; or software purpose-built for targeting and kinetic effects. The civilian accommodation business does not itself establish institutional military accommodation procurement.^{8, 9, 30}

Counter-Arguments and Evidence Limits

The company’s strongest defence in this domain is the civilian character of the documented services and the absence of identified defence contracts. Computer vision, commercial AI and reservation software cannot be reclassified as military systems without evidence of a military product, customer or deployment. Settlement geography likewise does not establish military-base operation.^{9, 3}

The Dutch complaint concerns alleged proceeds from settlement tourism, not arms exports or defence logistics. The ICC warrants concerned alleged individual responsibility of Benjamin Netanyahu and Yoav Gallant and were not proceedings against Booking Holdings or Booking.com. These distinctions support the fixed Military 0.00.^{17, 25}

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

The digital nexus is an attributable civilian technology footprint. Booking.com’s Tel Aviv operation publicly identifies work on recommendation systems, computer vision, natural-language understanding and reinforcement learning. Qlika supplied historical advertising-optimisation expertise integrated into Agoda; Evature supplied natural-language-processing and chatbot expertise associated with Booking.com’s Israeli engineering development.^{3, 4, 5, 31}

Agoda’s April 2024 corporate interview identifies CEO Omri Morgenshtern, CTO Idan Zalzberg and CPO Ittai Chorev as executives who joined after the Qlika acquisition. This establishes personnel and management continuity, without proving that Qlika’s original software remains deployed as a distinct platform.¹²

The July 2026 Tel Aviv event programme described domain-adapted travel language models and internally developed agentic infrastructure supporting more than 40 generative-AI use cases. Advertised applications included trip planning, search, traveller support and data enrichment. The programme does not establish that all models were trained from scratch or identify production datasets accessible from Israel. AI21 Labs’ participation establishes technical knowledge-sharing, not procurement, equity ownership or production integration.²⁷

Separately, Booking.com’s reservation platform digitally distributes settlement accommodation. Its privacy notice describes sharing reservation information with providers and international transfers needed for booking services. This establishes a commercial information-transfer mechanism, while transaction-specific routing, hosting and Israeli personnel access remain undisclosed.^{9, 15, 16}

Counter-Arguments and Evidence Limits

No public evidence identified of Booking Holdings supplying spyware, facial recognition, predictive policing, military surveillance, autonomous targeting or government sovereign-cloud services to Israeli institutions. No public evidence identified of participation in Project Nimbus or verified active procurement from the Israeli-origin cybersecurity vendors checked in the audit.

The disclosed AWS and Snowflake architecture does not establish Israeli hosting or state access. Likewise, international-transfer provisions and an Israeli engineering office do not establish access to identifiable customer records from Israel. The fixed Digital 6.60 rests on documented commercial technology operations and platform activity, with these limits preserved.^{3, 16, 32}

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

The economic mechanism is commercial reservation intermediation connecting travellers with settlement accommodation providers. Booking Holdings reports merchant, agency and advertising-related revenue streams; investigations identify settlement properties offered through Booking.com. The record supports an economic relationship without quantifying settlement-specific booking value, commissions or profit.^{8, 9, 20}

Historical and later counts must remain separate. Human Rights Watch recorded 26 properties outside East Jerusalem in July 2018; Amnesty recorded 45 providers with broader coverage in September 2018. Who Profits’ profile, valid through 30 November 2024, recorded 24 listings across 12 West Bank settlements, seven in occupied East Jerusalem neighbourhoods and 152 across 28 occupied Syrian Golan settlements. None is an independently verified October 2026 inventory.^{9, 14, 33}

The Guardian’s August 2024 dataset and Ekō’s May 2026 research provide later evidence. Ekō investigated 41 listings across 14 settlements, including two in Neve Daniel. For one property advertised as “Mountain View,” researchers combined listing coordinates, mapping layers and an archival land-registration extract to link the site to the Al-Sbeih family’s ownership claim. The Guardian separately interviewed Mohammad Al-Sbeih. This is traceable property-specific reporting, not a new judicial determination of title.^{15, 1, 2}

Counter-Arguments and Evidence Limits

Booking.com intermediates reservations; the evidence does not establish that it owns or directly operates the investigated hotels or apartments. Its general commercial model cannot establish the realised financial value of an individual listing. Ekō’s review totals and advertised nightly prices cannot reliably yield occupancy, completed bookings or commission income.^{29, 9, 2}

No public evidence identified of Israeli sovereign-debt underwriting, war-bond purchases, direct financing of military procurement, settlement-construction lending, agricultural procurement or Israeli manufacturing plants. Israeli tax payments, subsidiary profit transfers and settlement-specific revenue remain unquantified. The documented economic nexus is therefore narrower than general financing of the Israeli state.

The terminated eDreams relationship is also a material limit: Booking.com stated that it ended in September 2025. It cannot be treated as a continuing distribution partnership after that date.²⁶

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

The political nexus concerns settlement-related operating policy and governance. Booking Holdings’ 2026 proxy defended permitting legally allowed listings, providing destination information and conducting enhanced due diligence. The board opposed Proposal 6, which sought additional reporting on oversight of settlement-related human-rights risks, arguing that existing processes were sufficient and further reporting would impose expense and administrative demands.⁶

On 2 June 2026, Proposal 6 received 64,039,145 votes in favour, 558,090,578 against and 7,840,777 abstentions, with 39,596,274 broker non-votes. It was not approved. This establishes a governance decision about disclosure, rather than an express endorsement of military operations.⁷

Argos reported repeated employee petitions, approximately 300 signatures per petition and questions raised with CEO Glenn Fogel. Booking.com acknowledged removing a petition-related intranet post in 2021, explaining that it sought to prevent divisive political discussion while supporting employee expression. The 2025 reporting does not establish that the specific removal occurred again after July or November 2024.¹⁹

The record also includes settlement-warning disputes, UN database identification and the Dutch complaint. FMEP attributed changes in proposed warning terminology to Israeli governmental pressure; this remains the report’s account, not evidence of a formal state partnership. The UN settlement-business database is neither a criminal conviction nor a UN sanctions designation.^{23, 21}

Counter-Arguments and Evidence Limits

Booking.com’s strongest defence is its stated consistent global approach: traveller choice, compliance with applicable law, enhanced due diligence and removal where legally required. The board presented its opposition to Proposal 6 as a judgment about existing oversight, reporting duplication and cost.^{6, 30, 19}

The audits found no public evidence of an explicit corporate endorsement of Israeli military operations, verified conflict-specific lobbying, direct corporate military donations or dismissal of employees specifically for supporting Palestinian civilians. A UJA donor entry for “Amy and Glenn Fogel” does not conclusively identify the Booking executive, identify Booking Holdings as donor, disclose the precise contribution or establish military or settlement allocation. It is excluded as an established financing mechanism.^{34, 11}

Booking Holdings’ suspension of Russian and Belarusian travel services and its Ukraine refugee programme provide a documented comparison, but do not establish that the legal circumstances were identical or prove a motive for its settlement policy.^{35, 36}

The Dutch money-laundering allegations remain unresolved in the supplied record. The April 2026 Article 12 application was a procedural challenge to prosecutorial delay, not a conviction or established order requiring prosecution.^{17, 18}

Named Entities and Evidence Map

Counter-Arguments

The strongest defence is that Booking Holdings operates civilian marketplaces with independent providers, applies a worldwide legality-based listing policy and publishes human-rights commitments. The evidence does not establish property ownership, military supply, state control, military donations or a foundational geopolitical mandate. Historical acquisitions establish commercial technology relationships, not defence relationships.^{8, 29, 4, 5, 30, 22}

These limits coexist with repeated, attributable settlement-listing observations and documented decisions to maintain the company’s listing framework. The record supports scrutiny of those activities while leaving financial magnitude, disputed land claims and criminal allegations within their evidentiary limits. The eDreams termination is credited; no equivalent general settlement exit was documented.^{6, 1, 2, 18, 26}

Chronology also limits inference. SOMO’s 9 November 2024 observation followed the ICJ opinion but preceded the 21 November 2024 ICC warrants by 12 days. Post-warrant continuation must rest on later evidence, including the March 2025 and May 2026 reporting, rather than that earlier observation.^{24, 1, 19, 25}

Complicity Index Score

Method: V6.6 - final, human-vetted values.

• V_MAX: 7.00 Avg_OTHERS: 4.50
• BRS Score: 658 Tier: B (Severe Complicity)

Economic supplies V_MAX through documented settlement-accommodation intermediation, supported by the civilian digital footprint and settlement-related governance record.^{1, 2, 3, 6} The fixed Tier B assessment follows the corpus’s scale-free, evidence-only, vetted method; it does not convert unresolved allegations into findings or assign military involvement where the audit identified none.

Methodology Note

• This dossier compiles only the four supplied domain audits, including their supplemental corrections, caveats and exculpatory findings; it adds no independent research.
• Impact (I) concerns activity type under a scale-free framework; Magnitude (M) concerns scale; Proximity (P) concerns directness. The supplied V6.6 scores are reproduced without recalculation.
• Historical [pre-2020] activity is distinguished from later evidence. Exited or terminated relationships receive temporal mitigation; historical acquisitions do not establish current standalone software deployment.
• Attribution follows documented entities and relationships. Parent ownership, shared investors, executive names and technical interaction do not establish transitive responsibility for unrelated activities.
• Documented settlement operation is assessed in both Economic and Political. Listing counts remain tied to their dates, geography and methods; allegations are distinguished from adjudicated findings.
• “No public evidence identified” records negative findings within the reviewed audit scope. It does not assert that undisclosed activity is impossible.