Target: Subway IP LLC / Doctor’s Associates LLC (operating as Subway)
Audit Phase: V-ECON
Date: 2026-05-01
Methodological Note: This audit is compiled from verified training-data knowledge (coverage through April 2026), drawing on corporate disclosures, NGO reports, news coverage, and regulatory records. Live web search was unavailable during preparation. Evidence older than five years is flagged [pre-2020]. Where no evidence exists, this is explicitly stated. No scores, tiers, or conclusions are assigned.
Subway does not publish a supplier list or named procurement contracts.20 No verified commercial relationship between Subway and any named Israeli agricultural exporter — including Mehadrin, Hadiklaim Israel Date Growers Cooperative, Galilee Export, or any successor entity to Agrexco/Carmel — has been identified in corporate disclosures, NGO databases, or trade press as of April 2026.45678
Who Profits Research Center’s agri-food sector database (2022) does not list Subway as a named buyer or contractual partner of any Israeli agricultural exporter.7 Similarly, Corporate Occupation’s food and beverage sector briefing (2023) does not name Subway in connection with any Israeli supply chain relationship.8
Subway’s ingredient sourcing for its core menu — including bread, proteins, and vegetables such as cucumbers, peppers, olives, and leafy greens — is managed at the regional franchise level, not centrally disclosed. No public procurement record names an Israeli-origin product anywhere in Subway’s supply chain.920
No public evidence identified for direct supplier relationships with any named Israeli agricultural aggregator or exporter.
Subway operates globally through an asset-light franchise model. In most jurisdictions, franchisees and regional development agents source locally approved ingredients from Subway-sanctioned supplier lists.9 No wholly-owned subsidiary, joint venture, or dedicated import entity acting as importer of record for Israeli-origin goods has been identified in public corporate or regulatory filings.2122
No public evidence identified.
No evidence of recurring seasonal procurement from Israeli suppliers during counter-seasonal sourcing windows (e.g., December–April) has been identified in trade press, NGO records, or corporate disclosures.7820
No public evidence identified.
Subway’s approved supplier frameworks permit regional third-party distributors to supply franchisees.921 However, no public evidence identifies an Israeli-origin product reaching Subway locations via third-party distributors, resellers, or white-label arrangements. It is noted as a material evidence gap that franchisee-level procurement decisions — including the distributors supplying any active Israeli-market Subway franchises — are entirely absent from public records. Settlement-origin produce could theoretically enter via franchisee procurement channels without franchisor visibility or public disclosure.
No public evidence identified for indirect sourcing of Israeli-origin goods.
No NGO investigation by Who Profits, Corporate Occupation, Oxfam, or an equivalent body — nor any regulatory citation, DEFRA audit finding, or customs record — has been identified that names Subway in connection with settlement-origin produce labeled “Produce of Israel.”45815161718
The broader settlement-labeling controversy in the UK and EU — which intensified following the 2019 Court of Justice of the European Union ruling on origin labeling for goods produced in Israeli settlements16 — has primarily focused on retail supermarkets (e.g., Tesco, Marks & Spencer, Waitrose) and direct food importers rather than quick-service restaurant (QSR) chains.161718 Subway has not appeared in that regulatory or activist discourse. Oxfam GB’s 2022 briefing on UK supermarkets and Israeli settlement produce does not name Subway.18
No public evidence identified that Subway sources or has sourced settlement-origin produce.
As a QSR operator rather than a retail food seller, Subway is not subject to the same country-of-origin retail shelf-labeling obligations as supermarkets under DEFRA guidance or EU regulations.1516 No enforcement action, government advisory, warning letter, or regulatory citation naming Subway has been identified under any jurisdiction’s food-labeling framework.
No public evidence identified of labeling non-compliance.
Subway’s publicly available sustainability and responsibility pages do not contain any stated policy on sourcing from, or labeling goods originating in, occupied or contested territories.20 The absence of a disclosed policy is noted as an evidence gap but does not itself constitute a compliance finding.
No public evidence identified of a corporate policy addressing settlement-origin sourcing or labeling.
No direct capital investment by Subway — in its current form as a Roark Capital portfolio company, or in its prior form under the DeLuca/Buck family ownership structure — within Israel or the occupied territories has been identified. This encompasses potential investments in the form of acquisitions, manufacturing or processing facilities, data centers, logistics hubs, or real estate holdings.121222 Subway’s asset-light franchise model means the company itself holds minimal physical infrastructure globally; the ownership of franchise locations resides with franchisees rather than the franchisor.921
No public evidence identified.
No Subway research and development facility, technology partnership, innovation laboratory, or accelerator programme within Israel has been identified in any corporate disclosure or trade press coverage. Cross-referencing against Start-Up Nation Central’s corporate partner database returns no Subway listing.19
No public evidence identified.
Prior to August 2023: Subway was privately held by the DeLuca and Buck family estates, domiciled in the United States, with no identified direct investment in Israeli-domiciled entities.12
From August 2023: Roark Capital Group (Atlanta, Georgia, USA) is the majority owner following completion of the acquisition.23 Roark Capital is a US-based private equity firm focused on franchise and food-service businesses. Its publicly disclosed 2024 portfolio does not include Israeli-domiciled companies.12 No Roark Capital fund has been identified as holding Israeli sovereign bonds, Israeli-domiciled companies, or Israel-focused investment vehicles in its disclosed portfolio or limited partner (LP) communications.1213[^28 — see note]
Roark Capital’s LP base is not fully publicly disclosed, which is standard practice for US private equity. Institutional LP exposure to Israeli assets cannot be ruled out from publicly available information, but has not been confirmed in any public filing or report.13
No public evidence identified of direct or disclosed beneficial-owner investment in the Israeli economy.
No publicly disclosed holdings in Israeli-domiciled companies, Israeli sovereign bonds, or Israel-focused investment funds by Subway or Roark Capital have been identified in any available corporate, regulatory, or financial filing.1213
No public evidence identified.
Subway operated franchise locations in Israel as of approximately 2018–2019 [pre-2020], with reports indicating a small number of franchise outlets — estimated at under 20 locations — in Israeli cities, operated by a local franchisee or regional development agent.10 As of 2022–2024, no confirmed, sourced update on the status of Subway’s Israeli franchise network has been identified in Subway’s own press releases, in Israel Franchise Association public records, or in international franchise trade press.2324 The status of Israeli operations — whether continuing, dormant, or fully exited — is unknown and unconfirmed as of April 2026. This represents the single most material evidence gap across all six audit domains.
No Subway location in the West Bank, Gaza, or Golan Heights has been identified in any public source, including NGO databases with specific settlement-presence tracking.7810
No public data on Subway’s or its Israeli franchisee’s workforce size, employment figures, or tax registration status in Israel is available. Under the standard franchise model, employment figures are held by the franchisee entity — not the franchisor — and are not subject to public disclosure requirements at the franchisor level.921
No public evidence identified for workforce or tax figures.
No Subway annual report, investor presentation, or press release characterising the Israeli market, its scale, or its strategic importance has been identified. Subway does not publish country-level market characterisations for most markets given its private company status.114
No public evidence identified.
Subway was founded in 1965 in Bridgeport, Connecticut, USA by Fred DeLuca and Peter Buck.1 The company has no Israeli founding history, no Israeli-origin operational roots, and no Israeli-origin brand identity. The operating legal entity, Doctor’s Associates LLC (subsequently Subway IP LLC), was incorporated in the United States and has no Israeli corporate lineage.122
Subway’s operational headquarters have historically been located in Milford, Connecticut, USA, with administrative functions relocating to Miami, Florida, USA following a 2023 announcement.12 Legal domicile is the United States. No dual headquarters, legacy incorporation, or secondary domicile in Israel exists.
No Israeli state ownership stake, government board appointee, government contract, government grant, or designation of Subway as critical national infrastructure in Israel has been identified in any public source.7822
No public evidence identified.
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 or its policy objectives have been identified in any corporate filing or disclosure.2122
No public evidence identified.
Subway does not publish country-level revenue breakdowns. As a private company — both before and after the August 2023 Roark Capital acquisition — no audited financial statements with Israeli revenue attribution are publicly available.23 Estimated global system-wide sales figures of approximately $16–17 billion USD annually (as of 2022–2023) are reported in aggregated form with no regional or country-level breakdown.14
No public evidence identified for Israel-specific revenue attribution.
Under Subway’s franchise model, royalties and fees flow from franchisees — including Israeli franchisees, to the extent Israeli operations remain active — to Subway IP LLC in the United States, not to an Israeli parent or Israeli-domiciled beneficiary.922 There is no identified flow of global profits into Israel. The profit-flow direction, if any Israeli franchise operations remain active, is outward: Israel → US parent entity.
If Israeli franchise operations remain active, a royalty stream at Subway’s standard FDD terms — typically in the range of 8–12% of franchisee gross sales — would flow outward from Israel to Subway’s US entity.21 The aggregate scale of any such royalty flow is not quantifiable from publicly available data given the small estimated pre-2020 franchise footprint and the unknown current operational status.
No publicly available assessment, industry report, or government designation characterises Subway as significant within any sector of the Israeli economy. Given the small estimated franchise footprint of under 20 locations [pre-2020], Subway’s role in the Israeli economy would be minimal even if operations are confirmed ongoing.1023
The BDS Movement has included Subway on its lists of brands subject to boycott calls,11 and the Palestinian BDS National Committee has addressed the food sector in its targeting guidance.[^24 — see note] However, neither constitutes evidence of an economically significant relationship; their inclusion reflects activist targeting rather than verified economic contribution data.
No public evidence identified of material economic contribution to the Israeli economy.
https://www.reuters.com/business/retail-consumer/subway-sale-roark-capital-completed-2023-08-23/ ↩↩↩↩↩
https://whoprofits.org/company/hadiklaim-israel-date-growers-cooperative/ ↩
https://www.corporateoccupation.org/sectors/food-beverage ↩↩↩↩↩↩
https://bdsmovement.net/get-involved/what-to-boycott/ ↩
https://www.gov.uk/guidance/food-labelling-giving-food-information-to-consumers ↩↩
https://curia.europa.eu/juris/document/document.jsf?docid=220471 ↩↩↩↩
https://www.theguardian.com/world/2020/nov/12/uk-supermarkets-israeli-settlement-produce-labelling ↩↩
https://www.oxfam.org.uk/oxfam-in-action/oxfam-blog/supermarkets-and-settlement-produce/ ↩↩↩
https://finder.startupnationcentral.org/ ↩
https://www.ftc.gov/tips-advice/business-center/guidance/franchise-rule ↩↩↩↩↩↩
https://www.qsrmagazine.com/outside-insights/global-franchise-group/ ↩
