Audit Phase: V-MIL
Target Company: Fiverr International Ltd. (NYSE: FVRR)
Date of Audit: 2026-05-01
Fiverr International Ltd. has no publicly identified direct contractual relationship with the Israeli Ministry of Defence (IMOD), the Israel Defense Forces (IDF), the Israel Prison Service, or the Israel Border Police. Fiverr’s core business — a two-sided digital marketplace connecting freelancers with commercial buyers — does not correspond to any category of vendor that would ordinarily appear in IMOD procurement registries for goods or materiel.1
Fiverr’s annual reports on Form 20-F (FY2022, FY2023, FY2024), filed with the U.S. Securities and Exchange Commission, include detailed risk-factor disclosures covering Israel’s regulatory environment, geopolitical exposure, and the impact of armed conflict on business operations. None of these filings disclose a material government defence contract.23 The absence of such disclosure is forensically significant: SEC reporting rules for foreign private issuers require disclosure of material contracts, and a defence procurement relationship of any scale would satisfy that materiality threshold.
Fiverr does not appear in SIBAT (Israel Defence Export and Defence Cooperation Directorate) listings, international defence exhibition catalogues such as DSEI, Eurosatory, or ISDEF, or any Israeli or international defence procurement registry identified in publicly available sources.15 This structural absence is consistent with Fiverr’s identity as a digital marketplace facilitator rather than a goods manufacturer or service contractor to the security apparatus.
No corporate press release, government announcement, or trade publication has been identified that describes a formal defence cooperation agreement, joint venture, or partnership between Fiverr and any Israeli or foreign defence entity.23
The UN OHCHR database (HRC res. 31/36 / 53/25, most recent iteration 2023), which lists 112 business enterprises involved in specific activities related to Israeli settlements, does not include Fiverr International Ltd.25 The database focuses on companies involved in settlement construction, tourism, banking, and infrastructure; Fiverr’s business model falls outside all listed activity categories.
The UN Special Rapporteur’s July 2025 report A/HRC/59/23 (“From economy of occupation to economy of genocide”) addresses military, surveillance/carcerality, and civilian heavy machinery sectors in paragraphs 28–47. Based on training-data knowledge of this report’s scope and named-company analysis, Fiverr is not named in A/HRC/59/23; the report’s military-sector named companies are concentrated in defence manufacturing, weapons systems, and dual-use technology with documented kinetic applications.24 [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
The PAX Netherlands report Companies Arming Israel and Their Financiers (June 2024), which profiles companies supplying weapons, components, and military equipment to Israel, does not identify Fiverr in its named-company list, consistent with PAX’s methodology of focusing on companies with verified arms supply relationships.26 [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
The Al-Haq report Business and Human Rights in the Context of Israel’s Genocide in Gaza (July 2024), which addresses corporate complicity focusing on arms suppliers, infrastructure companies, and financial institutions, does not name Fiverr.27 [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
The Don’t Buy Into Occupation (DBIO) coalition reports focus on financial institutions and companies with direct settlement-linked revenue streams; no DBIO report naming Fiverr has been identified.31 The Corporate Occupation database, which profiles companies with verified operational roles in the occupation economy, contains no identified entry for Fiverr.
No public evidence identified of direct defence contracting or procurement by Fiverr International Ltd. This finding is confirmed across all Tier-1 authoritative sources checked in this expansion run.
Fiverr does not manufacture physical products of any kind. Its commercial offering is a digital services marketplace platform, supplemented by Fiverr Enterprise — a B2B workforce-management SaaS product (formerly Stoke Talent, acquired 2021) that enables enterprises to source, onboard, and manage freelance and contract workers.23 Neither product has a ruggedised, mil-spec, tactical, or otherwise defence-grade variant publicly documented.
The research memo assessed the claim — originating exclusively in prior unverified analytical text — that Fiverr’s proprietary matching algorithms were “repurposed” to “optimise Kill Chain logistics.” This claim is unverified and unsupported by any independent source. The NoCamels reporting from October 2023 describes Israeli high-tech companies broadly using digital infrastructure and AI tools to coordinate volunteer and supply logistics in the aftermath of the October 7 attacks, but does not attribute algorithmic retasking to Fiverr’s core commercial platform.4
Applying the V-MIL domain boundary for software and AI products: the inclusion threshold requires that a product’s designed output produce a targeting decision or weapons effect. Fiverr’s platform outputs are (a) freelancer-buyer service matches and (b) enterprise workforce management data. Neither output produces a targeting decision or weapons effect. Fiverr Enterprise is a general-purpose labour-market coordination tool. Neither product meets the V-MIL software/AI inclusion threshold. Surveillance tools, biometrics, and dual-use AI repurposed by the military without purpose-built kinetic design belong in V-DIG, not V-MIL.
Fiverr is not an exporter of controlled physical goods and does not appear in export licence databases in any reviewed jurisdiction. The company’s “exports” are digital services, which fall largely outside traditional dual-use export control frameworks, though EU and U.S. regulations on certain software and AI products may be technically applicable. No enforcement actions, licence applications, or regulatory correspondence related to dual-use export control have been publicly identified.23
The FY2024 annual report (filed March 2025), the first filing to cover the full post-ICJ Advisory Opinion period (post-19 July 2024) and partially the post-ICC arrest warrant period (post-21 November 2024), contains no new disclosure of defence contracts, dual-use product development, or military end-user relationships beyond the standard geopolitical risk-factor language present in prior filings, based on training-data knowledge of its contents.2 [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE — exact filing text requires live EDGAR retrieval]
No public evidence identified of militarised product variants, dual-use product lines, or end-user certification requirements applicable to Fiverr’s current product portfolio.
Fiverr does not manufacture, supply, lease, or service heavy machinery, construction equipment, military vehicles, or related physical infrastructure. This audit domain is structurally inapplicable to Fiverr’s business model.1
Source classes reviewed for completeness include the Who Profits Research Center corporate database,13 the AFSC Investigate platform,14 UN OCHA Occupied Palestinian Territory (oPt) reports,20 Amnesty International’s October 2023 reporting on Israeli military operations,21 and Human Rights Watch’s Israel/Palestine coverage.22 None of these sources, to the extent assessable through available training-data knowledge, reference Fiverr in any context relating to settlement construction, separation barrier maintenance, military installation infrastructure, or West Bank or Gaza construction activity.
Checking against the settlement nexus requirement (Principle 7): Fiverr’s corporate structure as known from SEC filings comprises Fiverr International Ltd. (Cayman Islands holding company), Fiverr Inc. (U.S. subsidiary), Fiverr Ltd. (Israeli operating entity), Fiverr Germany GmbH, and the Stoke Talent/Fiverr Enterprise entity. None of these subsidiaries are involved in construction, logistics, or infrastructure. The Israeli operating entity (Fiverr Ltd.) provides the local employment base and R&D operations; it has no documented construction or logistics function.123
A theoretical concern arises whether Fiverr’s marketplace could host freelancers operating from Israeli settlements in the West Bank, thereby generating revenue attributable to settlement economic activity. This is a V-DIG-domain question (platform governance and geographic revenue attribution) rather than a V-MIL question and is flagged here only for routing to the appropriate domain audit. No NGO report has identified this as a documented V-MIL concern.
No Israeli tender registry entry, IMOD procurement record, or NGO database entry connecting Fiverr to engineering or construction contracts in occupied or contested territory has been identified.
No public evidence identified of any heavy machinery, construction, or infrastructure activity by Fiverr in any jurisdiction relevant to this audit.
No verified supply relationship has been identified between Fiverr International Ltd. and any Israeli defence prime contractor, including Elbit Systems, Israel Aerospace Industries (IAI), Rafael Advanced Defense Systems, or Israel Military Industries/Elbit Land. Fiverr does not manufacture components, sub-systems, raw materials, or specialist outputs of the type that would appear in a defence prime’s certified supplier base.1314
The research memo examined a specific indirect-nexus argument advanced in prior unverified analytical text: that Dell Technologies is both a documented IMOD server supplier10 and an alleged user of Fiverr Enterprise, thereby implying a transitive supply-chain link to the Israeli defence industrial base. This argument is unverified. While Dell’s alleged Israeli government infrastructure contracts are separately reported,10 no public source corroborates that Dell specifically uses Fiverr Enterprise for workforce management. Even if such usage were confirmed, Fiverr Enterprise is a general-purpose freelance management platform deployed across multiple industry sectors globally; use by a defence-adjacent firm would not, without further evidence, constitute verified integration into a defence prime’s supply chain.
Checking the group attribution requirement (Principle 4 extension): Fiverr’s subsidiary and affiliate structure does not include any entity with a documented defence-prime supply relationship. Stoke Talent (acquired October 2021, rebranded Fiverr Enterprise) was a U.S.-incorporated SaaS company focused on enterprise freelance management; its pre-acquisition client base, to training-data knowledge, did not include Israeli defence primes. No Israel Innovation Authority grant records publicly linking Fiverr or its subsidiaries to defence-industrial R&D programmes have been identified.37 [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
No OECD National Contact Point complaint against Fiverr in any jurisdiction has been identified in training-data knowledge.35
No joint development programmes, co-production agreements, technology transfer arrangements, or licensed manufacturing agreements between Fiverr and any Israeli or international defence firm have been identified in SEC filings,23 trade press, Israeli patent registry reporting, or defence contractor supplier disclosures.
No public evidence identified of supply-chain integration between Fiverr and Israeli or international defence prime contractors.
Fiverr does not operate in the sectors of base catering, transport logistics, fuel supply, waste management, facilities maintenance, telecommunications infrastructure, or other support services to military installations. No contract — formal or informal — between Fiverr and IDF bases, military training facilities, detention centres, or security installations in Israel or the occupied Palestinian territories has been identified in any public source.23
No public evidence has been identified of Fiverr providing logistical sustainment services at any installation in the West Bank, Golan Heights, East Jerusalem, or the Negev. Fiverr does not operate in the shipping, freight forwarding, or port-handling sector, and no evidence places it in those supply chains.
The expansion research checklist items covering post-July 2024 continuation and the settlement nexus via subsidiaries add no new findings in this domain. Fiverr’s business model does not intersect with base-services categories in any configuration identified in public sources.
No public evidence identified of any logistical sustainment or base services engagement by Fiverr.
Fiverr is not a defence manufacturer, prime contractor, or component supplier. It has no publicly documented involvement in the design, manufacture, integration, maintenance, testing, or logistical support of any lethal system, weapons platform, or strategic capability.12
Source classes reviewed include Jane’s Defence procurement databases (via public reporting), Israeli defence industry trade press, SIBAT listings,15 SEC filings,23 and defence prime contractor supplier disclosures. None identify Fiverr in the context of:
A/HRC/59/23 paragraphs 28–47, which specifically address munitions and weapons-adjacent companies, do not include Fiverr among the companies discussed.24 [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
No public evidence identified of any involvement by Fiverr in munitions, weapons systems, or strategic platforms.
No government decision — in the United States, European Union, United Kingdom, or Israel — to grant, deny, suspend, or revoke an export licence for Fiverr’s products or services to Israeli military or security end-users has been identified in any public record.23
Fiverr’s annual 20-F filings acknowledge the applicability of Israel’s Defence Export Control Law (2007) to its operations as an Israeli-domiciled technology company. These are standard risk-factor disclosures filed by all Israeli tech companies listed on U.S. exchanges and do not indicate any specific licence application, regulatory inquiry, or enforcement action against Fiverr.23
Separately, Fiverr’s 20-F filings acknowledge standard OFAC and international sanctions compliance obligations arising from its role as a global payments-processing platform — specifically, the obligation to ensure that freelancer and buyer payments do not flow to sanctioned jurisdictions or designated persons. These disclosures relate to financial sanctions compliance, not arms trade or dual-use export control.23
No court proceedings, judicial review applications, or legal challenges brought against Fiverr or against any government body regarding Fiverr’s alleged defence supply relationship with Israel have been identified in any jurisdiction.
No investigations, citations, or enforcement actions against Fiverr by any export control authority (BIS, DDTC, ECJU, DECA, or Israeli DECA equivalent) related to arms embargo or military end-use compliance have been identified.
Post-ICJ Advisory Opinion (19 July 2024) — constructive notice:34 The ICJ’s Advisory Opinion held that Israel’s continued presence in the Occupied Palestinian Territory is unlawful under international law and that all states and international organisations are under obligations not to render aid or assistance in maintaining the illegal situation. This Opinion creates a constructive-notice threshold: activity continuing after 19 July 2024 that would otherwise assist the occupation can be assessed against a higher standard of diligence. In Fiverr’s case, no activity in the V-MIL domain has been identified that would trigger this analysis — there is no defence contract, arms supply, or construction activity to evaluate for post-July 2024 continuation. The constructive-notice framework is therefore inapplicable on current evidence.
Post-ICC arrest warrants (21 November 2024):33 The ICC Pre-Trial Chamber I issued arrest warrants for Prime Minister Netanyahu and former Defence Minister Gallant on 21 November 2024. This creates a second constructive-notice marker for this audit. In the absence of any identified V-MIL-domain activity by Fiverr, the post-November 2024 continuation analysis finds no activity to evaluate.
The FY2024 20-F filing (covering the period through 31 December 2024), the first filing to encompass both the post-ICJ Opinion and post-ICC warrant periods, contains no reported disclosure of regulatory or legal developments arising from those events that materially affect the company’s business or legal exposure, based on training-data knowledge.2 [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE — full filing text requires live EDGAR retrieval]
No public evidence identified of any export licensing action, regulatory proceeding, or legal challenge related to defence supply activity by Fiverr.
Who Profits Research Center13 focuses on companies with verified operational presence in the occupied territories or direct supply to the Israeli security apparatus. No published Who Profits profile for Fiverr International Ltd. has been confirmed in available training-data knowledge as of April 2026. The absence is consistent with Fiverr’s business model, but live database retrieval is required to confirm definitively.
AFSC Investigate14 profiles companies linked to Israeli military operations, settlement infrastructure, and arms supply. No confirmed published AFSC Investigate profile for Fiverr has been identified. The candidate AFSC URL for a Fiverr-specific entry14 was included in the source inventory but could not be confirmed as an active, populated entry.
Amnesty International21 and Human Rights Watch22 have published extensive reporting on Israeli military operations and the occupied Palestinian territories. Neither organisation has, to available knowledge, published a report specifically addressing Fiverr’s military, security, or dual-use supply chain relationship with the Israeli state.
UN OCHA oPt reports20 focus on settlement infrastructure, arms supply, and humanitarian impact. No UN report is known to specifically reference Fiverr.
PAX Netherlands (June 2024)26 and Al-Haq (July 2024)27 are the most substantive post-October 7 civil society reports addressing corporate complicity. Neither names Fiverr. [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
UN A/HRC/59/23 (Albanese, July 2025)24 does not name Fiverr based on training-data knowledge of the report’s scope and named-company analysis. [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
The most substantively documented civil-society-relevant activity concerns Fiverr’s corporate response to the October 7, 2023 attacks:
Micha Kaufman’s association with the Israel Growth Forum (IGF) — a consortium of Israeli tech company leaders interfacing with the Israel National Digital Agency19 — is corroborated by multiple contemporaneous sources.56 Kaufman’s role in post–October 7 IGF advocacy and his public statements on the war’s economic impact are documented.56 His profile on Aleph VC’s platform further documents his broader role in the Israeli tech ecosystem.9 A claim that Kaufman posted a tweet publicly donating to the IDF originates exclusively in prior unverified analytical text and has not been independently confirmed.
Through 2024 and into early 2025, Kaufman and other Israeli tech CEOs publicly advocated for a hostage-and-ceasefire deal, characterising the prolonged conflict as damaging to Israel’s economy and tech sector.36 This advocacy is directed at conflict resolution, not at expanding military operations, and does not constitute a co-belligerency statement in the V-MIL sense. No evidence has been identified that Kaufman or Fiverr’s board made any statement after the ICJ Advisory Opinion (19 July 2024) or ICC arrest warrants (21 November 2024) that constituted an endorsement of continued IDF operations or a public affirmation of defence-sector engagement by Fiverr. [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
The claim that Fiverr specifically activated a Ukrainian employee network to backfill Israeli reservists called up after October 7 is unverified. While Kaufman is known to have addressed remote work infrastructure in the context of the Ukraine conflict, the specific assertion of deliberate wartime workforce substitution has not been corroborated by any primary source available in training-data knowledge.
Shai Wininger — Co-Founder (non-executive): Wininger co-founded Fiverr in 2010 and later co-founded Lemonade Inc. (NYSE: LMND). He stepped back from Fiverr executive roles after IPO. No defence-board roles, defence-industry equity, or FIDF leadership roles have been identified in training-data knowledge for Wininger. [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
Yoav Shoham — Board Member: Shoham is a Stanford University professor and AI researcher and co-founder of AI21 Labs (an Israeli general-purpose large language model company). He is listed as a Fiverr board member.30 AI21 Labs is not a defence prime or security contractor. To training-data knowledge, AI21 Labs has not been identified in any NGO database or UN report as a company supplying purpose-built kinetic-effect AI systems to the IDF; this would in any event be a V-DIG consideration rather than V-MIL. No defence-board directorship, weapons-system involvement, or FIDF leadership role by Shoham in his Fiverr board capacity has been identified. [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
Institutional shareholders (≥10%): As of the most recent available proxy and 20-F filings, no single institutional shareholder holds ≥10% of Fiverr’s ordinary shares in a controlling capacity that would trigger Principle 4 group attribution. Major institutional holders (Fidelity, BlackRock, and similar) are passive financial investors.2832 No institutional controlling shareholder with a defence-supply nexus has been identified.
Board composition note: Fiverr’s proxy disclosures1828 identify the full board. No board member has been identified in training-data knowledge as holding a concurrent directorship at an Israeli defence prime (Elbit, IAI, Rafael, IMI) or as serving in an active military-command or FIDF national leadership capacity. [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
The Kosher Giving article (December 2023) documents an Engineers Without Borders Israel project to adapt homes of wounded IDF soldiers, naming corporate partners.7 The specific claim that Fiverr is a named partner in this project originates in prior unverified analytical text and cannot be confirmed without direct retrieval and reading of the source article.
Fiverr appears on informal boycott lists, including boycott-israel.org,12 which enumerates Israeli-founded and Israeli-headquartered technology companies broadly. The stated grounds are Fiverr’s Israeli corporate domicile and tax residence, not any identified defence supply relationship. Fiverr appears on these lists alongside other Israeli-headquartered technology firms including Wix,17 Monday.com, and Check Point, in the general context of BDS campaign targeting of Israeli tech.11
The BDS Movement’s active economic campaigns38 as of April 2026 target HP Inc./HPE (Israeli military IT), Caterpillar (bulldozers in occupied territories), Puma (Israeli Football Association sponsorship), Siemens (infrastructure contracts), and a rotating list of specific arms suppliers. Fiverr does not appear as a named target of a specific BDS economic campaign based on training-data knowledge. Fiverr’s appearance on general “Israeli tech company” boycott lists remains categorically distinct from a named BDS campaign tied to a specific military supply relationship.
No institutional divestment decision by a pension fund, sovereign wealth fund, endowment, or institutional investor — analogous to exclusion decisions by Norway’s GPFG specifically citing companies such as Elbit Systems or Caterpillar — specifically targeting Fiverr on grounds of identified defence-sector activity has been identified. [TRAINING-DATA — UNVERIFIED BY LIVE SOURCE]
No public evidence has been identified of corporate policy changes, contract terminations, end-use monitoring commitments, or specific public statements by Fiverr in response to civil society pressure regarding a defence supply chain relationship.23 Fiverr has not, to available knowledge, issued any corporate statement specifically addressing allegations of military complicity or responding to BDS campaign targeting.1823
https://www.sec.gov/Archives/edgar/data/1762301/000104746919003139/a2238508zf-1.htm ↩↩↩↩
https://www.sec.gov/Archives/edgar/data/1762301/000117891324000697/zk2430936.htm ↩↩↩↩↩↩↩↩↩↩↩↩↩
https://www.sec.gov/Archives/edgar/data/1762301/000117891323000458/zk2328076.htm ↩↩↩↩↩↩↩↩↩↩
https://nocamels.com/2023/10/israeli-high-tech-giants-use-ai-to-streamline-wartime-aid-delivery/ ↩↩↩
https://www.calcalistech.com/ctechnews/article/r1f14fkbn ↩↩↩
https://en.globes.co.il/en/article-israels-tech-industry-enlists-1001460259 ↩↩↩
https://koshergiving.com/2023/12/04/engineers-without-borders-israel-rehabilitating-the-idfs-wounded-on-the-homefront/ ↩
https://www.aleph.vc/content/micha-kaufman ↩
https://brusselsmorning.com/does-dell-support-israel-role-in-military-and-tech-sectors/76644/ ↩↩
https://en.wikipedia.org/wiki/Boycott,_Divestment_and_Sanctions ↩
https://boycott-israel.org/boycott.html ↩
https://www.reddit.com/r/Fiverr/comments/1md4a54/discussion_fiverr_and_the_gaza_conflict/ ↩
https://www.jewishnews.co.uk/website-builder-wix-helps-unite-the-worlds-support-for-israel/ ↩
https://investors.fiverr.com/corporate-governance/governance-documents ↩↩
https://www.gov.il/en/departments/israel_digital_agency ↩
https://www.amnesty.org/en/latest/news/2023/10/israel-opt-damning-evidence-of-war-crimes-as-attacks-on-civilians-continue-in-israel-and-occupied-palestinian-territory/ ↩↩
https://documents.un.org/doc/undoc/gen/g25/117/72/pdf/g2511772.pdf ↩↩↩
https://www.ohchr.org/en/hr-bodies/hrc/regular-sessions/session31/database-business-enterprises ↩
https://paxforpeace.nl/publications/companies-arming-israel-and-their-financiers/ ↩↩
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001762301&type=DEF+14A&dateb=&owner=include&count=10 ↩↩
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001762301&type=6-K&dateb=&owner=include&count=40 ↩
https://hai.stanford.edu/people/yoav-shoham ↩
https://dontbuyintooccupation.org/ ↩
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001762301&type=SC+13&dateb=&owner=include&count=10 ↩
https://www.icc-cpi.int/news/situation-state-palestine-icc-pre-trial-chamber-i-rejects-state-israel-challenges-admissibility ↩
https://www.icj-cij.org/case/163 ↩
https://www.oecdwatch.org/complaints/ ↩
https://www.timesofisrael.com/ ↩
https://innovationisrael.org.il/en/ ↩
https://bdsmovement.net/act/economic-action-campaigns ↩
