Target: Booking Holdings Inc. Relevant subsidiaries: Booking.com B.V. and associated travel-platform businesses. Evidence cut-off: 26 October 2026.
Direct Defence Contracting & Procurement
Corporate operations and procurement scope
Booking Holdings’ 2025 annual filing identifies an online travel and reservation business whose principal services include accommodation, flights, rental cars, and other travel-related bookings. Its listed significant subsidiaries include Booking.com B.V., Agoda, KAYAK, Priceline, and OpenTable; the filing does not identify a defence manufacturing or procurement business segment.1, 2
Israeli Ministry of Defence and military contracts
No public evidence identified of a contract, framework agreement, tender award, or memorandum of understanding between Booking Holdings or its identified subsidiaries and the Israeli Ministry of Defence, Israel Defense Forces, Israel Prison Service, Israel Border Police, or another Israeli state security organisation.
Defence trade directories
No public evidence identified of Booking Holdings or Booking.com appearing as a defence supplier in SIBAT procurement or export records, Israeli defence exhibition catalogues, or other identified military-industry supplier directories.
Official defence cooperation announcements
No public evidence identified of an announced defence joint venture, military partnership, or government defence procurement programme involving Booking Holdings.
Relevant civilian operating relationship
Booking.com maintained a wholly owned Israeli support subsidiary that assisted accommodation providers, including operators of properties in settlements. Amnesty International documented its role in communicating with property operators and advising them on how to promote accommodation listings in its January 2019 investigation. The documented service was civilian accommodation intermediation; the investigation did not identify a military procurement contract. This historical evidence is [pre-2020].3
Controlling principals
Booking Holdings’ 2026 proxy identifies Glenn D. Fogel as CEO and director and Robert J. Mylod Jr. as board chair. It identifies institutional shareholders including Vanguard and BlackRock, each below 10% beneficial ownership in the reported table.4
No public evidence identified establishing an Israeli defence contract, military-industry directorship, military-support donation, or defence procurement activity attributable to a covered controlling principal or identified personal vehicle.
The company’s 2025 proxy provides an additional historical governance and ownership reference, while its corporate leadership disclosures identify executive and board appointments. These disclosures do not establish a qualifying Israeli military procurement relationship.5, 6
Dual-Use Products & Tactical Variants
Commercial product classification
Booking Holdings’ principal disclosed products are online platforms facilitating reservations and associated travel services. Its 2025 Form 10-K describes digital travel marketplaces rather than manufacturers of physical equipment or purpose-built military systems.1
Militarised products
No public evidence identified of ruggedised, tactical, military-standard, or defence-grade product variants developed or marketed by Booking Holdings for Israeli security forces.
Civilian-to-military distinction
Human Rights Watch reproduced Booking.com’s 28 September 2018 statement describing its international accommodation reservation platform and explaining that the company did not itself purchase or resell accommodation inventory. This documented commercial activity does not identify military customers or military-specific adaptations. The statement is [pre-2020].7
Military artificial intelligence and targeting systems
No public evidence identified of Booking Holdings developing or supplying autonomous targeting, fire-control, kill-chain automation, precision-guidance, or other software purpose-built to produce kinetic military effects.
End-user certification
No public evidence identified of an Israeli military end-user certificate, controlled dual-use equipment transfer, or defence-specific export authorisation for Booking Holdings products.
Military leave and charitable matching
No public evidence identified establishing defence-specific reservist salary subsidies, donations to Israeli military-support organisations, or corporate charitable matching for such organisations by Booking Holdings or its covered controlling principals.
Heavy Machinery, Construction & Infrastructure
Heavy machinery and construction equipment
No public evidence identified of Booking Holdings manufacturing, selling, distributing, or financing heavy machinery used to construct or demolish settlements, checkpoints, military facilities, or the separation barrier.
Construction and engineering contracts
No public evidence identified of Booking Holdings holding construction, maintenance, engineering, or demolition contracts for Israeli military installations or settlement infrastructure.
Documented settlement-related commercial operations
Human Rights Watch’s November 2018 investigation documented Booking.com accommodation listings within Israeli settlements in the occupied West Bank. These were civilian tourism properties rather than military construction projects. The investigation is historical [pre-2020], and the relevant accommodation-listing business was subsequently documented again by other investigators.7
Amnesty International reported in January 2019 that its September 2018 research identified 45 Booking.com accommodation providers in settlements across East Jerusalem and 20 other West Bank locations. It documented accommodation promotion and commercial relationships with property hosts, without attributing construction or demolition contracts to Booking.com. This evidence is [pre-2020].3
AFSC’s company investigation reported that, as of 2022, Booking.com listed accommodation in 19 West Bank settlement locations, including East Jerusalem, and 25 locations in the occupied Syrian Golan Heights. These findings concern tourism services and accommodation listings rather than military installations or heavy equipment.8
Continued settlement-related activity
SOMO reported on 16 January 2025 that supplementary evidence submitted to Dutch prosecutors on 18 December 2024 documented an increase in Booking.com listings in East Jerusalem settlements from 13 on 9 November 2023 to 39 on 9 November 2024. The figures establish the complainants’ reported observations on those dates rather than a continuously measured daily inventory.9
The 9 November 2024 observation occurred after the ICJ Advisory Opinion of 19 July 2024 but 12 calendar days before the International Criminal Court issued arrest warrants for Benjamin Netanyahu and Yoav Gallant on 21 November 2024. The observation therefore provides evidence of reported settlement-listing activity after the ICJ opinion but does not independently establish continuation after the ICC warrants.9, 10
The ICC’s 21 November 2024 warrants concerned alleged individual responsibility for war crimes and crimes against humanity. The warrant announcement was not a proceeding against Booking Holdings or Booking.com.10
SOMO’s February 2026 investigation continued to identify the distribution of accommodation listings in Israeli settlements through online tourism platforms and reported Booking.com’s statement that its commercial and technical relationship with eDreams ended in September 2025. This establishes a dated commercial distribution relationship, with termination reported by the company, rather than military logistics activity.11
The February 2026 publication provides a later evidentiary context for settlement-related tourism services; it does not change the observation date of SOMO’s 9 November 2024 listing comparison.9, 11
Direct and indirect supply
The investigated settlement-related service consisted of accommodation listings, promotion, and reservation intermediation. Human Rights Watch and Amnesty International documented commercial platform relationships with accommodation providers, but their reports did not establish that Booking Holdings supplied machinery or construction materials to settlement developers. The underlying investigations are [pre-2020].3, 7
No public evidence identified of machinery transferred to settlement developers by Booking Holdings through authorised dealers, distributors, or secondary-market resale.
Supply Chain Integration with Defence Primes
Israeli defence manufacturers
No public evidence identified of Booking Holdings supplying products, components, materials, or specialist services to Elbit Systems, Israel Aerospace Industries, Rafael Advanced Defense Systems, or Israel Military Industries.
Components and manufacturing services
No public evidence identified of Booking Holdings supplying optical equipment, electronics, communications modules, propulsion components, armoured structures, guidance equipment, or other defence-specific manufacturing inputs.
Joint development and technology transfer
No public evidence identified of military technology-transfer agreements, licensed weapons production, defence research programmes, or co-production agreements involving Booking Holdings and Israeli defence manufacturers.
Corporate group boundaries
Booking Holdings’ 2025 SEC subsidiary exhibit identifies Booking.com B.V., Agoda, KAYAK, Priceline-related entities, and OpenTable as significant subsidiaries, with the exhibit explicitly excluding certain individually insignificant subsidiaries. These documented ownership relationships do not establish a defence manufacturing or supply-chain integration relationship.2
Directors and related commercial interests
Booking Holdings’ corporate leadership biographies and SEC proxy disclosures identify outside roles in technology, finance, retail, telecommunications, and other commercial sectors. No public evidence identified of a specifically attributable transaction linking a covered Booking Holdings principal or identified personal investment vehicle to the Israeli defence-industrial supply chain.4, 5, 6
No public evidence identified of a defence-specific joint venture, weapons manufacturing investment, or defence-prime component-supply arrangement attributable to an operationally integrated Booking Holdings subsidiary.
Logistical Sustainment & Base Services
Military accommodation services
Booking.com’s documented business model includes accommodation reservations. Its published human rights policy states that accommodation operators may generally list properties where this complies with applicable laws and that the company applies heightened due diligence to listings in conflict-affected and occupied territories. Neither the published policy nor the reviewed settlement investigations establishes a military accommodation procurement agreement.12, 7
No public evidence identified of Booking Holdings holding an accommodation, hotel procurement, travel-management, or military-base support contract with the IDF or Israeli Ministry of Defence.
Military installation support
No public evidence identified of catering, waste management, fuel delivery, facility maintenance, telecommunications, or operational support contracts at Israeli military bases, detention centres, or training establishments.
Transport and freight
No public evidence identified of military cargo transportation, freight forwarding, port handling, weapons shipment coordination, or military supply-chain services performed by Booking Holdings or its identified subsidiaries.
Occupied-territory geography
AFSC documents Booking.com’s historical civilian accommodation listings in occupied West Bank and Golan Heights settlements. The documented relationship concerns tourism facilities and settlement accommodation operators; it does not identify military-base operations or military transport services.8
Commercial intermediary
SOMO reported in February 2026 that Booking.com stated its eDreams partnership ended in September 2025. The published information identifies a tourism distribution relationship and does not establish a military freight, procurement, or sustainment contract.11
Military accommodation end-users
No public evidence identified establishing that the Israeli Ministry of Defence, IDF, Israel Prison Service, or another military or security organisation procured accommodation through Booking Holdings for operational or institutional purposes.
Munitions, Weapons Systems & Strategic Platforms
Weapons manufacturing
No public evidence identified of Booking Holdings manufacturing, integrating, licensing, distributing, or servicing weapons supplied to Israeli military forces.
Ammunition and precursor materials
No public evidence identified of Booking Holdings supplying ammunition, explosives, chemical propellants, warhead materials, or munitions precursors to Israeli defence customers.
Strategic weapons systems
No public evidence identified of Booking Holdings participating in the production, integration, operation, or maintenance of Iron Dome, David’s Sling, Arrow, Israeli military aircraft, armoured vehicles, warships, or ballistic missile systems.
Critical military components
No public evidence identified of Booking Holdings supplying radar components, guidance electronics, fire-control systems, propulsion equipment, weapons integration software, or other critical components for lethal military platforms.
Kinetic military software
No public evidence identified of Booking Holdings providing software specifically designed to generate military targets, direct weapons, automate engagement decisions, or produce kinetic weapons effects.
Export Licensing, Regulatory & Legal History
Defence export licences
No public evidence identified of an export licence granted, denied, suspended, or revoked for Booking Holdings products intended for Israeli military or security end-users.
Defence-related sanctions enforcement
No public evidence identified of Booking Holdings being investigated, cited, sanctioned, or prosecuted for violations of arms embargoes or military export-control restrictions concerning Israel.
Settlement-related legal proceedings
SOMO’s case chronology records that SOMO, Al-Haq, the European Legal Support Center, and The Rights Forum filed a criminal complaint against Booking.com with the Dutch Public Prosecution Service on 8 November 2023. The complaint alleges money laundering involving proceeds from accommodation listings in Israeli settlements. These are allegations concerning settlement-tourism revenues; the complaint is not presented as a defence-export or weapons-supply proceeding.13
The Business & Human Rights Resource Centre’s case chronology records that Dutch prosecutors indicated in May 2024 that they intended to investigate the complaint. It also records that Booking.com disputed the allegations and that subsequent proceedings remained ongoing in 2026.14
SOMO reported that supplementary evidence was submitted on 18 December 2024 and publicly described the submission on 16 January 2025. The material included accommodation-listing observations dated 9 November 2023 and 9 November 2024.9
On 8 April 2026, the complainant organisations initiated an Article 12 procedure asking the Dutch Court of Appeal to address the prosecutor’s failure to decide whether to proceed with the criminal complaint. SOMO published the procedural development on 9 April 2026.15
Independent reporting published on 12 April 2026 likewise described the application to compel a prosecutorial decision, without reporting a criminal conviction or final judicial determination establishing Booking.com’s liability.16
Corporate legal position
Booking Holdings’ published Human Rights FAQs state that its platforms generally permit accommodation listings where applicable law allows them and that the group conducts heightened due diligence in conflict-affected or occupied territories. The company describes a case-by-case approach to potential adverse human rights impacts.12
Human Rights Watch reproduced Booking.com’s September 2018 response asserting that its platform permits accommodation operators to list properties where this complies with applicable legislation. The company disputed the characterisation of its reservation platform as providing services that support settlement maintenance. This response is [pre-2020].7
SOMO’s January 2025 publication reproduced Booking.com’s stated position that it would permit listings unless applicable domestic law prohibited them. This is the complainants’ published account of the company’s position, rather than an independently established court finding.9
Military-related litigation
No public evidence identified of a judicial proceeding against Booking Holdings specifically concerning military equipment, weapons exports, IDF procurement, or defence logistics.
Civil Society Scrutiny & Documented Investigations
United Nations settlement-business database
The UN High Commissioner for Human Rights published its initial settlement-business database on 12 February 2020. AFSC’s reproduction of the published company list identifies both Booking.com B.V. and Booking Holdings Inc. among the named enterprises. The database concerns specified settlement-related business activities and does not itself establish military weapons or defence procurement relationships.17
Amnesty International’s February 2020 response identified Booking.com among digital tourism companies included in the UN settlement-business database and referred to its earlier investigation of settlement tourism. Amnesty’s discussion concerned tourism and settlement business activity rather than military contracting.18
Human Rights Watch investigation [pre-2020]
Human Rights Watch’s November 2018 report, prepared with research contributions from Kerem Navot, investigated online accommodation rentals in West Bank settlements. It documented Booking.com’s listings and reproduced the company’s response. The findings concern tourism services and settlement economic activity.7
Amnesty International investigation [pre-2020]
Amnesty International’s January 2019 Destination: Occupation investigation identified 45 Booking.com accommodation providers in settlements as of September 2018. It described Booking.com’s Israeli support subsidiary, direct interactions with property operators, and inconsistent geographic labelling of accommodation locations.3
Amnesty’s accompanying January 2019 publication criticised the role of online tourism companies, including Booking.com, in promoting visits to settlement destinations and generating commercial activity. The report did not identify Booking.com as an Israeli military equipment supplier.19
AFSC company investigation
AFSC’s Booking Holdings company profile documents settlement accommodation listings in the West Bank and Golan Heights, the Israeli subsidiary’s accommodation-provider support activities, the company’s responses to criticism, and historical divestment campaigns. The profile identifies settlement tourism as the relevant commercial activity.8
AFSC describes its Investigate database as covering companies with documented links to specified human rights concerns, using corporate filings, public records, NGO investigations, and other sources. Inclusion in the database does not independently establish a particular defence contract or military supply relationship.20
Institutional divestment and organised campaigns
AFSC records that the University of Manchester divested from companies associated with Israeli settlement activity in August 2020, including Booking.com. Its profile also records student-government divestment resolutions adopted at San Francisco State University and Fresno State University in 2020 concerning companies listed in the UN settlement database. These actions concerned settlement involvement rather than Booking Holdings’ military equipment supply.8
No public evidence identified of an institutional divestment decision specifically attributable to Booking Holdings’ supply of weapons, military components, kinetic targeting software, or military-base services to Israel.
Continued activity after international legal developments
SOMO’s 16 January 2025 publication reports that settlement accommodation listings increased from 13 on 9 November 2023 to 39 on 9 November 2024 in the relevant East Jerusalem locations. Its dated observations establish reported continued settlement-related commercial activity after the ICJ Advisory Opinion of 19 July 2024.9
Human Rights Watch’s announcement dated 21 November 2024 confirms that the ICC issued arrest warrants for Benjamin Netanyahu and Yoav Gallant on that date. Consequently, SOMO’s 9 November 2024 observation preceded the warrants by 12 calendar days; it cannot independently establish post-warrant continuation.9, 10
SOMO’s February 2026 investigation documents later scrutiny of accommodation distribution in settlements and reports Booking.com’s explanation concerning the September 2025 termination of its eDreams relationship. This later investigation is distinct from the November 2024 listing comparison and concerns civilian tourism services.11
SOMO’s April 2026 publication confirms that the complainant organisations continued pursuing the Dutch criminal complaint through the Article 12 procedure. The proceeding concerns alleged proceeds from settlement accommodation activity and was not reported as a defence procurement case.15
Corporate policies and responses
Booking Holdings’ published Human Rights FAQs describe a general policy of allowing legally permissible listings while undertaking heightened due diligence in conflict-affected, disputed, or occupied territories. The company states that it may take appropriate action where listings are linked to adverse human rights impacts.12
Booking Holdings’ corporate governance disclosures identify its leadership and board responsibilities, while its 2025 annual filing describes its principal travel-related business activities. No public evidence identified of a defence-specific end-use monitoring commitment, termination of an Israeli military contract, or corporate policy addressing the supply of kinetic military technology to Israeli forces.1, 4
Footnotes
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Booking Holdings Inc., Form 10-K for the fiscal year ended 31 December 2025, SEC, 2026. https://www.sec.gov/Archives/edgar/data/1075531/000107553126000009/bkng-20251231.htm ↩ ↩2 ↩3
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Booking Holdings Inc., Exhibit 21, List of Subsidiaries as of 31 December 2025, SEC, 2026. https://www.sec.gov/Archives/edgar/data/1075531/000107553126000009/bkng12312510kex21.htm ↩ ↩2
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Amnesty International, “Chapter 4: Online Tourism Companies Doing Business in the Settlements”, Destination: Occupation, 30 January 2019. https://www.amnesty.org/en/latest/campaigns/2019/01/chapter-4-online-tourism-companies-doing-business-in-the-settlements/ ↩ ↩2 ↩3 ↩4
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Booking Holdings Inc., 2026 Proxy Statement, SEC, April 2026. https://www.sec.gov/Archives/edgar/data/1075531/000130817926000310/bkng-20260420.htm ↩ ↩2 ↩3
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Booking Holdings Inc., 2025 Proxy Statement, SEC, 2025. https://www.sec.gov/Archives/edgar/data/1075531/000130817925000476/bkng013642-def14a.htm ↩ ↩2
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Booking Holdings Inc., “Leadership and Board of Directors”, corporate website, accessed 26 October 2026. https://www.bookingholdings.com/about/leadership/ ↩ ↩2
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Human Rights Watch, “Bed and Breakfast on Stolen Land: Tourist Rental Listings in West Bank Settlements”, 20 November 2018. https://www.hrw.org/report/2018/11/20/bed-and-breakfast-stolen-land/tourist-rental-listings-west-bank-settlements ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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American Friends Service Committee, “Booking Holdings Inc.”, AFSC Investigate, research information principally current to 10 August 2022. https://investigate.afsc.org/company/booking-holdings ↩ ↩2 ↩3 ↩4
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SOMO, “Additional evidence filed against Booking.com for profiting from illegal settlements”, 16 January 2025. https://www.somo.nl/additional-evidence-filed-against-booking-com-for-profiting-from-illegal-settlements/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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Human Rights Watch, “Palestine: ICC Warrants Revive Hope for Long-Delayed Justice”, 21 November 2024. https://www.hrw.org/news/2024/11/21/palestine-icc-warrants-revive-hope-long-delayed-justice ↩ ↩2 ↩3
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SOMO, “Profiting from tourism in illegal Israeli settlements”, February 2026. https://www.somo.nl/profiting-from-tourism-in-illegal-israeli-settlements/ ↩ ↩2 ↩3 ↩4
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Booking Holdings Inc., “Human Rights FAQs”, corporate website, accessed 26 October 2026. https://www.bookingholdings.com/about/compliance-and-ethics/human-rights-faqs/ ↩ ↩2 ↩3
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SOMO, “Booking.com accused of laundering profits from Israeli war crimes in Palestine”, case chronology published 23 May 2024 and subsequently updated. https://www.somo.nl/booking-com-accused-of-laundering-profits-from-israeli-war-crimes-in-palestine/ ↩
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Business & Human Rights Resource Centre, “Booking.com lawsuit” case chronology, accessed 26 October 2026. https://www.business-humanrights.org/en/latest-news/elsc-v-bookingcom/ ↩
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SOMO, “Israel: Court must decide on prosecution of Booking.com over money-laundering”, 9 April 2026. https://www.somo.nl/court-must-decide-on-prosecution-of-booking-com-over-money-laundering/ ↩ ↩2
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NL Times, “Human rights organizations seek charges against Booking.com over Israeli settlement rentals”, 12 April 2026. https://nltimes.nl/2026/04/12/human-rights-org-seek-charges-bookingcom-israeli-settlement-rentals ↩
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American Friends Service Committee, “UN list of companies involved in illegal Israeli settlements in the Occupied Palestinian Territory”, 14 February 2020. https://investigate.afsc.org/updates/un-list ↩
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Amnesty International, “Israel/OPT: UN list of settlement businesses offers new hope for accountability”, 13 February 2020. https://www.amnesty.org/en/latest/news/2020/02/israelopt-un-list-of-settlement-businesses-offers-new-hope-for-accountability/ ↩
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Amnesty International, “Israel/OPT: Tourism companies driving settlement expansion, profiting from war crimes”, 30 January 2019. https://www.amnesty.org/en/latest/news/2019/01/israel-opt-tourism-companies-driving-settlement-expansion-profiting-from-war-crimes/ ↩
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American Friends Service Committee, “AFSC Investigate Methodology”, accessed 26 October 2026. https://investigate.afsc.org/methodology ↩