INDEX / DIRECTORY / SAP / ECONOMIC

SAP ECONOMIC

ECONOMIC AUDIT UPDATED 2026-08-27
Economic Score 7.00 /10 B SAP - BDS-1000 731
Economic 7.00

Evidence-only forensic audit. Scoring happens downstream - see the main dossier for the composite assessment.

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Economic Audit: SAP

Supply Chain & Sourcing Relationships

No public evidence identified. SAP’s 2024 Form 20-F, Israel office pages, Israel legal/privacy materials, cloud infrastructure materials, and SAP’s 2025 Form 20-F materials reviewed in the memo did not disclose procurement of Israeli agricultural products, use of Israeli produce importers of record, or recurring seasonal sourcing from Israeli agricultural suppliers.1234

No public evidence identified. The reviewed materials also did not disclose a dedicated SAP import entity for goods originating from Israel or the occupied territories, and they did not evidence indirect or white-label sourcing of Israeli-origin consumer goods through SAP-operated retail channels.124

The reviewed record is materially oriented toward software, cloud, office, R&D, and acquisition activity rather than procurement of physical consumer goods or food supply chains.15634

Product Origin, Labeling & Regulatory Compliance

The memo’s document-scoped review states that SAP was not mentioned in the OHCHR 2023 update, the OHCHR 2025 update, or the UN document A/HRC/59/23, which supports only an absence within those specific records rather than a broader exoneration.789

No public evidence identified. The reviewed sources did not show SAP selling settlement-origin consumer products, facing public country-of-origin labeling disputes, being subject to DEFRA or customs actions over such goods, or publishing a product-labeling policy specific to goods from occupied territories.12789

The same evidence pattern is consistent with SAP’s business profile in the memo, which centers on enterprise software, cloud services, R&D, and acquisitions rather than sale of consumer merchandise requiring origin labeling at point of sale.1631011

SAP’s current product-localization pages show active Israel-specific legal and tax functionality in SAP software, including Israel-specific business and legal functions for SAP S/4HANA and a workflow for submitting electronic invoices to Israeli tax authorities through SAP Document and Reporting Compliance.121314

Those localization materials evidence software adaptation for the Israeli market rather than settlement-origin consumer-product activity.121314

Investment, Capital & Financial Exposure

SAP’s 2024 Form 20-F lists multiple Israeli-domiciled subsidiaries at 100% ownership, including SAP Israel Ltd., SAP Labs Israel Ltd., SAP Portals Israel Ltd., Loyalsys Technologies Israel Ltd., and WalkMe Ltd..1

SAP’s 2025 Form 20-F and XBRL subsidiary materials still list SAP Israel Ltd., SAP Labs Israel Ltd., SAP Portals Israel Ltd., Loyalsys Technologies Israel Ltd., and WalkMe Ltd. at 100% ownership, with WalkMe Ltd. listed in Tel Aviv-Yafo, Israel, showing post-acquisition continuity into 2025 year-end.41516

SAP announced on 2024-06-05 that it had entered into an agreement to acquire WalkMe Ltd. for approximately US$1.5 billion, and SAP announced on 2024-09-12 that the transaction had been completed.1011

SAP’s 2025 Form 20-F states that SAP financed the WalkMe acquisition with a short-term loan in September 2024 and repaid that loan in March 2025.4

WalkMe’s investor FAQ states that the company’s corporate headquarters is in Tel Aviv, Israel, linking that acquisition directly to an Israeli-headquartered target.17

WalkMe’s 2023 Form 20-F states that WalkMe is organized under the laws of the State of Israel, is registered with the Israeli Registrar of Companies, is headquartered at 1 Walter Moses St., Tel Aviv, and had about 1,000 full-time employees as of 2023-12-31.18

SAP’s acquisitions and corporate history pages identify earlier Israeli acquisition activity, including OFEK-Tech in 2000, TopTier Software in 2001, and TopManage Financial Solutions in 2002.1920

SAP’s history page describes TopTier as “Israel’s market leader” in enterprise portals, indicating that SAP’s Israeli acquisition activity included established local software assets rather than only small experimental investments.20

A 2001 Globes report stated that SAP acquired TopTier for US$400 million and that TopTier would become a wholly owned SAP subsidiary.21

A 2002 Globes report stated that SAP acquired TopManage and attributed to SAP’s CFO a purchase price of less than US$10 million.22

SAP’s acquired-brands material states that SAP acquired Gigya in 2017 and integrated its software into SAP customer-data offerings, confirming acquisition of another Israel-linked brand lead, although the reviewed current sources did not cleanly verify a present separate Israeli Gigya operating subsidiary.23

SAP’s current Labs page states that SAP Labs Israel, founded in 1998, now plays a central role in SAP Business AI and leads work in areas including multi-cloud strategy, UX, and privacy.6

SAP News reported in 2020 that SAP.iO Foundry Tel Aviv ran a utilities-focused accelerator cohort that would collaborate with Israel Electric Corp. as a beta-site partner.24

SAP’s 2024 Form 20-F also lists Israeli-related non-subsidiary equity or fund exposures under “Other Equity Investments,” including Data.R.X. Ltd. (Datricks Ltd.), Tel Aviv, BioCatch Ltd., Tel Aviv, and 83North IV, L.P., Herzliya.1

The same filing states that SAP had €6.545 billion in total equity investments and €1.1 billion in total venture-capital-fund commitments as of 2024-12-31, placing those Israeli-linked exposures within a broader balance-sheet investment portfolio.1

SAP’s 2025 integrated-report exhibit states that Sapphire Ventures places “particular focus” on companies and venture funds in Europe, Israel, the UK, and the US, adding current context for SAP-linked venture exposure that includes Israel.25

No public evidence identified. The reviewed materials did not show SAP holding Israeli sovereign bonds, underwriting Israeli sovereign debt, selling Israel Bonds, or disclosing a Preferred Technology Enterprise status in Israel.12264

Operational Presence & Market Activity

SAP’s current Israel office-locations page lists SAP Israel Ltd. at 14 Eli Hurvitz Street, Ra'anana, Israel.5

SAP’s Israel visitor registration and identity management privacy statement lists SAP Israel Ltd., SAP Labs Ltd., and SAP Portals Ltd. as controllers for SAP premises in Israel, all at Ra’anana, and states that SAP Labs Ltd. also has a Tel-Aviv facility at Derech Menachem Begin 132.2

SAP’s current Israel impressum page separately names SAP Israel Ltd. at 14 Eli Hurvitz, Raanana.27

SAP’s current Labs page states that SAP Labs Israel was founded in 1998 and remains an SAP R&D location.6

SAP’s broader current Labs page states that SAP Labs Israel, founded in 1998, plays “a central role” in SAP Business AI and has developed products including SAP BTP, SAP Business Data Cloud, SAP Build, and SAP Customer Data Platform.28

SAP’s cloud infrastructure materials identify data-center presence in Tel Aviv, Israel, with both the 2025 cloud-services data-center PDF and the 2025 C5 materials including Israel and Tel Aviv in their infrastructure disclosures.329

The 2025 IATI company-profile booklet lists SAP Labs Israel Ltd. as having approximately 1000 employees in Israel and describes the Israeli R&D center as operating across Ra'anana and Tel Aviv.26

SAP’s current office-location page lists Loyalsys Technologies Ltd. in Tel Aviv-Yafo under Emarsys Offices, and SAP’s 2025 SEC subsidiary table lists Loyalsys Technologies Israel Ltd., Tel Aviv-Yafo, Israel at 100% ownership.516

SAP is continuing to host Israel-market events from its Ra’anana office, with the 2026 SAP Connect Day for Spend Management Israel page listing the venue as SAP Offices, 14 Eli Hurvitz Street, Raanana.30

A 2017 SAP Community post stated that SAP in Israel served customers including the Government of Israel, the Israel Defense Forces, and the Bank of Israel, but the memo notes that no underlying contract records or current filing-level confirmation were identified in the reviewed materials.311

SAP’s 2024 Form 20-F does not present an Israel-specific revenue line item, and the memo found no description of Israel as a separately reported strategic market in that filing.1

No public evidence identified. The reviewed materials did not verify direct SAP operations inside West Bank settlements, East Jerusalem settlements, or the Golan Heights.789

SAP’s 2024 PartnerEdge contractual territories guide assigns Israel to SAP Israel Ltd. and assigns Palestine to SAP Middle East & North Africa LLC, but that document is a channel-territory guide and does not itself evidence settlement activity.32

Corporate Structure & Foundational Ties

SAP SE’s 2024 Form 20-F states that the company is incorporated in the Federal Republic of Germany and gives its principal executive offices in Walldorf, Germany.1

SAP’s 2025 Form 20-F likewise states that SAP SE remains incorporated in the Federal Republic of Germany with principal executive offices in Walldorf, Germany.4

SAP’s history materials state that the company entered Israel through the acquisition of OFEK-Tech in 2000 and added Israeli-founded TopTier in 2001, while SAP’s current Labs page states that SAP Labs Israel was founded in 1998.61920

SAP’s 2024 Form 20-F shows continued 100% ownership of SAP Israel Ltd., SAP Labs Israel Ltd., SAP Portals Israel Ltd., Loyalsys Technologies Israel Ltd., and WalkMe Ltd., indicating that SAP’s Israeli corporate footprint is embedded through wholly owned subsidiaries rather than loose reseller relationships alone.1

SAP’s 2025 Form 20-F and XBRL subsidiary materials continue to show those same Israeli entities at 100% ownership, including WalkMe Ltd. in Tel Aviv-Yafo, Israel.1516

The 2024 Form 20-F identifies Dietmar Hopp as a 5.1% beneficial shareholder and BlackRock, Inc. as a 6.3% beneficial shareholder, and it states that none of the major shareholders have special voting rights and that SAP is not aware of arrangements that could later result in a change of control.1

SAP’s 2025 Form 20-F repeats major-shareholder disclosure listing Dietmar Hopp at 5.1% and BlackRock, Inc. at 6.3%, and no Israeli beneficial owner at or above 5% was identified in that disclosure.4

No public evidence identified. The reviewed governance and shareholder disclosures did not show Israeli state ownership stakes, Israeli government board appointment rights, or charter or golden-share mechanisms structurally tying SAP SE to the Israeli state.14

No public evidence identified. The reviewed filings and targeted official-domain materials did not show Preferred Technology Enterprise status, Israel Innovation Authority grant awards, or comparable Israeli state-aid or tax-benefit designations for SAP or SAP Labs Israel.14

SAP’s supplier-enablement accounts-payable contacts PDF lists Israeli bill-to entities and registration numbers for SAP Labs Israel Ltd., SAP Portals Israel Ltd., and SAP Israel Ltd., indicating active local billing and registration infrastructure.33

Profit Repatriation & Economic Contribution

SAP’s 2024 Form 20-F does not disclose Israel-specific revenue, and the memo states that SAP’s public geographic revenue reporting is aggregated above the Israel-country level.1

SAP’s 2025 Form 20-F likewise does not disclose Israel-specific revenue, indicating that public geographic reporting remains above the Israel-country level in the reviewed annual reports.4

The same filing consolidates multiple Israeli subsidiaries as 100%-owned group companies, but the reviewed materials do not separately quantify dividends, remittances, or profit transfers into or out of Israel.1

SAP’s 2025 reporting and XBRL subsidiary materials continue to show multiple wholly owned Israeli subsidiaries, but the reviewed materials still do not separately quantify dividends, remittances, or profit transfers into or out of Israel.416

The 2025 IATI booklet characterizes SAP Labs Israel as a significant Israeli R&D employer with approximately 1000 employees and quotes its managing director describing SAP as a “key player” in Israel’s tech scene, which the memo treats as an attributed industry-association statement rather than a government designation.26

SAP’s office, labs, privacy, infrastructure, and event disclosures together support an economic footprint in Israel through offices, R&D functions, cloud infrastructure, local legal entities, and employment presence.56232926282730

SAP’s 2025 integrated-report exhibit states that acquired companies including WalkMe are still in a “transition period” and not yet obliged to follow certain SAP policies, which is current integration-status evidence rather than a separate revenue disclosure.25

No public evidence identified. The reviewed sources did not show SAP being formally designated as Israeli critical national infrastructure.1524

No public evidence identified. The reviewed materials also did not disclose Israeli state-aid awards, Israel Innovation Authority grants, or formal tax-benefit status specific to SAP.12264

Footnotes

  1. https://www.sap.com/docs/download/investors/2024/sap-2024-annual-report-form-20f.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16 ↩17 ↩18 ↩19 ↩20

  2. https://www.sap.com/mena/about/legal/privacy/visitor-identity-management/israel.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  3. https://www.sap.com/docs/download/agreements/product-use-and-support-terms/cls/en/list-of-data-centers-for-sap-cloud-services-english-v.1-2025.pdf ↩ ↩2 ↩3 ↩4 ↩5

  4. https://www.sec.gov/Archives/edgar/data/1000184/000110465926020058/sap-20251231x20f.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14

  5. https://www.sap.com/uk/about/company/office-locations/israel.html ↩ ↩2 ↩3 ↩4 ↩5

  6. https://www.sap.com/israel/about/company/innovation/labs.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  7. https://www.ohchr.org/sites/default/files/documents/hrbodies/hrcouncil/sessions-regular/session31/database-hrc3136/23-06-30-Update-israeli-settlement-opt-database-hrc3136.pdf ↩ ↩2 ↩3

  8. https://www.ohchr.org/en/press-releases/2025/09/un-human-rights-office-updates-database-businesses-involved-israeli ↩ ↩2 ↩3

  9. https://www.un.org/sexualviolenceinconflict/wp-content/uploads/2025/07/HRC-59-23.pdf ↩ ↩2 ↩3

  10. https://news.sap.com/2024/06/sap-enters-agreement-to-acquire-walkme/?amp=1 ↩ ↩2

  11. https://news.sap.com/2024/09/sap-completes-walkme-acquisition/ ↩ ↩2

  12. https://help.sap.com/docs/SAP_S4HANA_ON-PREMISE/8684a9474f284ef0a2207fc66d4d97f7/e28a962ae8a64656a5574f9ebd488e71.html ↩ ↩2

  13. https://help.sap.com/docs/SAP_S4HANA_ON-PREMISE/8684a9474f284ef0a2207fc66d4d97f7/4e8682139d034d36b9285b1d1f503a84.html ↩ ↩2

  14. https://help.sap.com/docs/SAP_S4HANA_CLOUD/4977e7737cc747edb51d806619e3d146/8c9d527ea4c94dd991515f11be735304.html?locale=en-US ↩ ↩2

  15. https://www.sec.gov/Archives/edgar/data/1000184/000110465926020058/R214.htm ↩ ↩2

  16. https://www.sec.gov/Archives/edgar/data/1000184/000110465926020058/R85.htm ↩ ↩2 ↩3 ↩4

  17. https://ir.walkme.com/shareholders/investor-faqs/ ↩

  18. https://www.sec.gov/Archives/edgar/data/1847584/000117891324000974/zk2431111.htm ↩

  19. https://www.sap.com/investors/en/resources/acquisitions.html ↩ ↩2

  20. https://www.sap.com/about/company/history/2001-2010.html ↩ ↩2 ↩3

  21. https://en.globes.co.il/en/article.aspx?did=482115 ↩

  22. https://en.globes.co.il/en/article-570441 ↩

  23. https://www.sap.com/israel/products/acquired-brands/what-is-gigya.html ↩

  24. https://news.sap.com/2020/10/sap-io-foundry-tel-aviv-innovation-utilities/?amp=1 ↩

  25. https://www.sec.gov/Archives/edgar/data/1000184/000110465926024381/tm2529416d2_ex99-1.htm ↩ ↩2

  26. https://iati.co.il/wp-content/uploads/2025/01/Booklet-2025.pdf ↩ ↩2 ↩3 ↩4 ↩5

  27. https://www.sap.com/israel/about/legal/impressum.html ↩ ↩2

  28. https://www.sap.com/about/company/innovation/labs.html ↩ ↩2

  29. https://www.sap.com/about/trust-center/certification-compliance/2025-h1-central-cloud-services-c5-report.html ↩ ↩2

  30. https://events.sap.com/il-sap-connect-day-for-spend-management-il/en_us/home.html ↩ ↩2

  31. https://community.sap.com/t5/additional-blog-posts-by-sap/sln-spotlight-sap-labs-israel-spirit-of-the-start-up-nation/ba-p/13331101 ↩

  32. https://assets.cdn.sap.com/agreements/leveled-partner-agreements/CTSSR/sap-partneredge-contractual-territory-guide-english-v2-2024.pdf ↩

  33. https://assets.cdn.sap.com/agreements/supplier-portal/ariba-supplier-enablement/sap-accounts-payable-contacts-global-english.pdf ↩