Economic Audit: Subway

Audit Phase: Economic Subject Entity: Subway (operating entities: Doctor’s Associates LLC; Subway IP LLC) Headquarters: Dual global headquarters, Miami, Florida and Shelton, Connecticut, United States Ultimate Owner (from 30 April 2024): Affiliates of Roark Capital Group (Atlanta, Georgia, USA) Audit Date: June 2026 Evidence Base: Subway corporate press releases, mainstream and trade press, encyclopedic records, NGO/BDS targeting databases, and franchise-industry reporting. Evidence-only; no scoring, interpretation, or conclusions are recorded.

Supply Chain & Sourcing Relationships

Direct Supplier Relationships

Subway does not publish a global supplier list or named procurement contracts, and ingredient sourcing is managed at the franchise/regional level under franchisor-sanctioned supplier frameworks.¹ No current commercial relationship between Subway and any named Israeli agricultural exporter (e.g. Mehadrin, Hadiklaim, Galilee Export, or any successor to Agrexco/Carmel) has been identified in corporate disclosures, NGO databases, or trade press.²³

During Subway’s historical Israeli operating period (1992–2004), reporting indicates the then-active Israeli franchise sourced certain ingredients from Israeli food producers, including dairy products from Tnuva, an Israeli dairy cooperative, in order to meet kashrut requirements.⁴⁵ This relationship is documented as belonging to the pre-2004 operating period, which terminated when the Israeli franchise closed (see Operational Presence).⁴⁶

No named Israeli agricultural aggregator or settlement-origin supplier has been identified in connection with Subway’s current global supply chain.

Importer of Record Structure

Subway operates an asset-light global franchise model in which franchisees and regional development agents source locally approved ingredients from franchisor-sanctioned supplier lists.¹ No wholly-owned subsidiary, joint venture, or dedicated import entity acting as an importer of record for Israeli-origin goods has been identified in public corporate or regulatory records.¹ No public evidence identified.

Seasonal Sourcing Patterns

No public evidence identified of recurring seasonal procurement from Israeli suppliers during counter-seasonal sourcing windows by Subway or its franchisees.

Third-Party & Indirect Sourcing

Subway’s approved-supplier frameworks permit regional third-party distributors to supply franchisees.¹ No public evidence identifies any Israeli-origin product reaching Subway locations via third-party distributors, resellers, or white-label arrangements in the current period. No public evidence identified.

Product Origin, Labeling & Regulatory Compliance

Settlement-Origin Products

No NGO investigation (Who Profits, Corporate Occupation, Oxfam, or equivalent), regulatory citation, customs record, or DEFRA audit finding has been identified that names Subway in connection with settlement-origin produce labelled “Produce of Israel.”²³⁷ Subway does not appear among the companies named in the BDS Movement’s corporate boycott-targeting guidance, which lists fast-food brands such as McDonald’s, Burger King, Papa John’s, Pizza Hut and Domino’s but not Subway.⁷ No public evidence identified.

Labeling Compliance

As a quick-service restaurant operator rather than a retail food seller, Subway is not the subject of any identified country-of-origin retail shelf-labelling enforcement action, government advisory, or regulatory citation under any jurisdiction’s food-labelling framework in relation to Israeli or settlement-origin goods.⁷ No public evidence identified.

Corporate Labeling Policy

No publicly disclosed Subway corporate policy specifically addressing sourcing from, or labelling of goods originating in, occupied or contested territories has been identified.¹ No public evidence identified.

Investment, Capital & Financial Exposure

Foreign Direct Investment

No direct capital investment by Subway - under its current Roark Capital ownership or its prior DeLuca/Buck family ownership - within Israel or the occupied territories has been identified, including acquisitions, manufacturing or processing facilities, data centres, logistics hubs, or real estate.⁸⁹ Subway’s asset-light franchise model means the franchisor holds minimal physical infrastructure globally, with franchise locations owned by franchisees.¹ No public evidence identified.

R&D & Innovation Centres

No Subway research and development facility, technology partnership, innovation laboratory, or accelerator programme within Israel has been identified. Subway’s disclosed innovation function (an Innovation Center and Mock Restaurant) is located at its Miami, Florida headquarters.¹⁰ No public evidence identified of any Israel-based facility.

Parent & Beneficial Ownership Flows

Subway was privately held by the DeLuca and Buck family interests (United States) until its sale to affiliates of Roark Capital Group, an Atlanta, Georgia private-equity firm, which was announced on 24 August 2023 and completed on 30 April 2024 at a price of approximately $9.55 billion.⁸⁹¹¹ Roark Capital’s publicly described portfolio is concentrated in US franchise/food-service platforms (including Inspire Brands and Focus Brands holdings such as Dunkin’, Arby’s, Buffalo Wild Wings, Jimmy John’s, Auntie Anne’s, Cinnabon and others).¹²¹³ No Israeli-domiciled company, Israeli sovereign bond, or Israel-focused investment vehicle has been identified in Roark Capital’s publicly described portfolio.¹²¹³

Roark Capital’s limited-partner base is not fully publicly disclosed, which is standard for US private equity; institutional LP exposure to Israeli assets is therefore not confirmable from public records and has not been identified in any public filing.¹² No public evidence identified of disclosed beneficial-owner investment in the Israeli economy.

Portfolio & Fund Exposure

No publicly disclosed holdings in Israeli-domiciled companies, Israeli sovereign bonds, or Israel-focused investment funds by Subway or Roark Capital have been identified.¹²¹³ No public evidence identified.

Operational Presence & Market Activity

Physical Footprint

Subway entered the Israeli market in 1992, opening what was described as the world’s first kosher Subway operation, and expanded to a peak of 23 branches across Israel.⁴⁵⁶ The Israeli operation closed in 2004, with reporting attributing the closure to the death of the original franchisee/manager and associated managerial and cost challenges.⁴⁵⁶ Encyclopedic records list Subway among defunct restaurant chains in Israel.⁶

Multiple subsequent attempts to re-enter the Israeli market did not result in operating restaurants:

• In May 2009, investor Gur Gal purchased Israeli franchise rights, leased space in Herzliya, negotiated for a Tel Aviv (Rothschild Boulevard) location and announced plans for up to 130 branches; the planned locations never opened, and a dispute between Gur Gal and Subway was settled in arbitration with no details released.⁶
• In June 2014, Subway publicly expressed renewed interest in the Israeli market and sought franchisees; no operating restaurants resulted.⁶

Public reporting current to November 2025 indicates Subway maintains no operational franchises in Israel.⁶ No Subway location in the West Bank, Gaza, or the Golan Heights has been identified in any reviewed source.²³⁶

Employment & Tax Contribution

With no identified active Israeli operations, no current Subway or franchisee workforce, employment figures, or tax-registration status in Israel has been identified. Under the franchise model, such figures would in any case rest with a franchisee rather than the franchisor and are not subject to franchisor-level public disclosure.¹ No public evidence identified.

Market Positioning

No Subway investor presentation, press release, or market characterisation identifying Israel as a current or strategic market has been identified; Subway’s disclosed regional emphasis from its Miami headquarters references Latin America operations.¹⁰ No public evidence identified of Israel as a current operating or strategic market.

Corporate Structure & Foundational Ties

Founding & Incorporation History

Subway was founded in 1965 in Bridgeport, Connecticut, USA, by Fred DeLuca and Peter Buck.¹⁴ The operating legal entities (Doctor’s Associates LLC; Subway IP LLC) are US-incorporated, and the brand has no Israeli founding, incorporation, or operational origin.⁹¹⁰¹⁴ No public evidence identified of Israeli corporate lineage.

Headquarters & Domicile

Subway operates dual global headquarters in Miami, Florida (opened March 2023) and Shelton/Connecticut, United States, and its legal domicile is the United States.¹⁰ No dual headquarters, legacy incorporation, or secondary domicile in Israel has been identified.¹⁰ No public evidence identified.

State & Institutional Linkages

No Israeli state ownership stake, government-appointed board member, government contract, government grant, or designation of Subway as critical national infrastructure in Israel has been identified.²⁶ No public evidence identified.

Structural Governance Features

No golden shares, founder shares, charter restrictions, special voting rights, or other governance mechanisms tying Subway’s operations or strategic mission to the Israeli state have been identified in any reviewed source.⁸⁹ No public evidence identified.

Profit Repatriation & Economic Contribution

Revenue Attribution

Subway does not publish country-level revenue breakdowns and is privately held (before and after the 2024 Roark Capital acquisition), so no audited financial statements with Israel-specific revenue attribution are publicly available.⁹¹¹ With no identified active Israeli operations, no Israel-specific revenue is identifiable. No public evidence identified of Israel-specific revenue attribution.

Profit Flows

Under Subway’s franchise model, royalties and fees flow from franchisees to Subway’s US entities (Subway IP LLC / Doctor’s Associates LLC), not to an Israeli-domiciled beneficiary.¹¹⁰ With no identified active Israeli franchise operations, no current royalty or fee flow either into or out of Israel has been identified.⁶ No public evidence identified of a current Israel-directed profit flow.

Economic Ecosystem Role

No publicly available assessment, industry report, or government designation characterises Subway as significant within any sector of the Israeli economy. Subway’s documented Israeli economic footprint is historical (a peak of 23 franchised outlets, closed in 2004) and no current operating presence has been identified.⁴⁶ No public evidence identified of current material economic contribution to the Israeli economy.

End Notes