Had your permit to employ a foreign worker revoked? A practical guide to the grounds, the hearing, and the appeal — for employers.
A decision by the Population and Immigration Authority to revoke an employment permit for a foreign worker is an administrative decision with immediate consequences. For the family of a nursing-care patient, it means that the caregiver who has accompanied their family member, sometimes for years, may no longer work for them. For a business employer, it means the loss of manpower, along with a refusal of future permit applications for a period that can reach three years.
This guide is intended for the employer's side: for the nursing-care patient and family members who have received a hearing letter or a revocation decision, and for business owners who have encountered administrative enforcement. It is important to clarify that this is a separate process from the proceeding to revoke the foreign worker's own work licence, which is conducted before the Appeals Tribunal for immigration matters.
The authority to revoke an employment permit is anchored in Section 1טו of the Foreign Workers Law, 5751-1991. Under Section 1טו(a), where an employer has failed to meet a condition set in the permit, an instruction under the Law, or a duty owed to its employees, or has unlawfully withheld a foreign worker's identity document or passport, the Supervisor may, after giving the employer an opportunity to state its case, revoke the permit in whole or in part, and on this ground alone refuse the employer's applications for a period not exceeding three years. The "Supervisor" for this purpose is the Director-General of the Population and Immigration Authority.
The exercise of this authority is regulated by Procedure 9.9.0001 (Procedure for Administrative Enforcement against Holders of Permits to Employ Foreign Workers), Version 2 of 3 March 2022. Two clarifications in it matter to anyone who has already been fined: clause ה.4 provides that an administrative fine, a financial sanction, or an indictment do not prevent the exercise of the revocation authority, and clause ה.5 adds that the administrative process does not affect the criminal process — paying a fine does not "close" the administrative file. Conversely, clause ה.3 of the Procedure, following Section 1יד1 of the Law, provides that no permit will be granted to an employer who has not paid a final administrative fine or financial sanction — a fine for which the deadlines to challenge it have passed without a challenge being filed, or whose challenge was rejected.
The most common ground is a breach of a permit condition or of a duty owed to the worker: failure to pay lawful wages, failure to deposit social benefits, failure to pay National Insurance contributions, failure to provide suitable housing or a weekly day of rest, and unlawfully withholding a passport. Procedure 9.5.0002 (Procedure on Permit Conditions for Employing Foreign Workers in the Trade and Services Sector) provides, in clause ה.17, that a material breach of the worker's rights may lead to revocation of the permit subject to a hearing under Section 1טו, and, in clause ה.5, that the Authority may revoke a permit, subject to a hearing, where the employer does not comply with the procedures or the permit conditions.
A second ground is a "serious offence" under Section 1טו(a2) — an offence under Sections 375א, 376, or 377א of the Penal Law (holding a person in conditions of slavery, forced labour, trafficking in persons), or another offence committed against a foreign worker that, "by its nature, severity, or circumstances, renders the employer unfit to receive a permit to employ a foreign worker".
In the nursing-care sector, the review is very practical. Procedure 9.2.0002 (from July 2024) provides, in clause ד.4, that a permit will be granted only to a patient who needs care or supervision for most hours of the day throughout a full working week, so employment that is not full-time will not be permitted; clause ד.5 requires suitable housing in the patient's home; and clause ד.6 provides that transferring the worker to work for a third party, even a family member, constitutes a breach of the permit conditions.
Under clause ג.1 of Procedure 9.9.0001, hearing proceedings under Section 1טו are conducted in writing. Clause ג.2 provides that the hearing letter will state a near-term date for submitting a response, given the urgency of the process — and the timelines are short. Clause ג.3 is the important warning: if the employer does not respond by the deadline, the Supervisor may decide based solely on the administrative evidence in the hearing letter.
The response to the hearing is therefore the real opportunity. It should address the substance of the matter and attach supporting documents: proof of wage deposits to the worker's bank account, proof of payments to the National Insurance Institute, the employment contract, medical insurance, and pay slips. Clause ב.10 allows the Authority to demand documents from the employer directly or through the placement agency — and in the nursing-care sector, it is worth verifying yourself that the documents were indeed transmitted. At the end of the process, clause ד.2 requires that the reasoned decision be sent to the employer or their representative, stating the competent forum and the deadline for filing a petition.
The Procedure allows for a graduated range of responses, not only full revocation. Clause ד.5 of Procedure 9.9.0001 provides that if the Supervisor decides not to revoke the full quota, they may condition the continuation of the permit on requirements — including a deposit of a guarantee to secure the workers' rights, or limiting the permit to employing workers already present in Israel; clause ב.2 allows conditions and restrictions to be set even before a decision on revocation; and clause ב.5 allows the decision to be postponed for up to 18 months where an investigation into a serious offence has been opened against an interested party or a senior officeholder of the employer. Proposing a supervision framework in response to the hearing — monthly reporting and documented deposits — is sometimes the best way to avoid revocation.
In the nursing-care sector there is an additional restraint: clause ב.6 provides that a permit will not be revoked due to the conviction of an interested party or a senior officeholder for a serious offence, except after the possibility of setting permit conditions to prevent harm to the worker has been examined. When revocation appears unavoidable, it is worth requesting the application of clause ב.9: temporary approval to continue employing the workers who were employed before the decision, for a period not exceeding three months, if this is necessary for their protection. Conversely, clause ד.4 clarifies that the employer has no vested right to bring in a foreign worker from abroad, and the Authority has discretion not to approve bringing in new workers when a hearing, investigation, or indictment is pending.
Revocation of the permit is directed at the employer, not at the worker. The District Court sitting as the Court for Administrative Affairs clarified, in a petition brought by a nursing-care patient and their worker, that the decision focuses on withdrawing the permit granted to the patient, and this does not negate the worker's right to apply for a work licence with another patient — although such an application will also be examined in light of the circumstances of the revocation.
The impact on the worker is nonetheless real. Once their regulated employment ends, they have about 90 days available to arrange lawful employment with another employer holding a valid permit in the same sector, under Section 11(א1) of the Entry into Israel Law, 5712-1952. And when the Appeals Tribunal grants the worker an "organizing period," it may bound that period by the date of the final decision on the patient's permit. This was illustrated in Adm. Appeal (Jerusalem) 56596-03-26 (2 Jul 2026): the appeal was dismissed, but the worker was given time to organize, bounded by the date of the ruling on the permit — and once the permit was revoked, that period also expired. It is therefore worth coordinating the two proceedings in advance, rather than managing them separately.
A decision of the Supervisor under Section 1טו is not challenged by an appeal to the Appeals Tribunal, but by an administrative petition to the District Court sitting as the Court for Administrative Affairs. Clause ד.2 of the Procedure requires the Authority to state in the decision the competent forum and the statutory deadline for filing — read this line carefully, since a delay may result in dismissal on threshold grounds for undue delay (laches).
Since the decision takes effect immediately, a motion for an interim order freezing it pending the ruling should be considered already when the petition is filed; as a rule, the fate of such a motion depends on the strength of the administrative arguments and the balance of convenience, and it should not be treated as a routine step. The main grounds of challenge are defects in the hearing process, an insufficient factual basis, unreasonableness, and disproportionality — particularly the length of the period of refusal of a future permit. That said, the court does not substitute its own discretion for that of the Authority, so as a rule a focused argument on proportionality is better founded than a general argument against the decision itself.
In Adm. Petition (Jerusalem) 21062-01-22 (15 Feb 2023), a company's permit was revoked and a three-year refusal period was set, after its owner was convicted of employing a worker without a permit. It was held that employing a worker without a permit is a "serious offence" also in the sense of an offence committed against the worker, since it defeats the supervisory framework meant to protect them; but the petition was granted in part, and the refusal period was shortened to a year and a half on proportionality grounds — the offence was lighter than those referred to in the definition, and the information had been given to the Authority by the employer itself. The lesson: proportionality is the real battleground.
In Adm. Petition (Jerusalem) 30035-02-24 (2 May 2024), the court reviewed a decision restricting the permit of a nursing-care patient who had left Israel for extended periods without the worker accompanying him. The petition was dismissed: in practice, there was no full-time employment as required by clause ד.4 of the nursing-care Procedure, and it made no difference whether the absence originated in the patient's leave or the worker's leave. Note that here the Authority chose to restrict the permit rather than revoke it.
In Adm. Petition (Jerusalem) 18882-09-24 (12 May 2025), a nursing-care patient's permit was revoked for three years due to ongoing doubt about the payment of wages and social benefits. The patient had previously been given "one more chance," conditioned on producing monthly deposit confirmations, and failed to meet it; even after the court mediated an arrangement that would have allowed the permit to be restored in exchange for National Insurance confirmations and bank statements, the documents were not submitted in full. The lesson: ongoing, orderly documentation of payments is the best defence.
And in Adm. Petition (Jerusalem) 23527-05-25 (3 Sep 2025), a joint petition by a patient and his worker was dismissed. In a home visit conducted by social workers, it was found that the worker was not present, that the home contained none of his personal belongings, and that there was no room designated for his residence — and this administrative evidence was found sufficient. The court remarked to the Authority that it would have been proper to attach the home-visit report already to its initial response; a reminder that demanding the full administrative record is a sound first step.
Our office assists nursing-care patients and their family members, as well as business employers, in administrative enforcement proceedings under Section 1טו of the Foreign Workers Law. We build the response to the hearing together with the client — gathering supporting documents, examining the administrative evidence underlying the hearing letter, and proposing a supervision framework that would allow the permit to be restricted rather than revoked — and in cases where the decision has already been given, we file an administrative petition and a motion for an interim order, coordinating between the employer's proceeding and the worker's proceeding. Every case is examined on its merits, and we do not guarantee an outcome.
Under clause ג.1 of Procedure 9.9.0001, hearing proceedings under Section 1טו are conducted in writing, among other reasons to avoid disputes over how the administrative evidence and arguments about it are presented. The Procedure does not grant a right to an oral hearing, and clause ג.3 adds that if a person does not submit their response by the deadline, the decision in their case may be made based solely on the evidence in the hearing letter. You should therefore respond in writing, by the date set, and attach supporting documents; a request for an oral hearing is not a substitute for a substantive response.
No. Clause ה.4 of Procedure 9.9.0001 expressly provides that imposing an administrative fine or a financial sanction, or filing an indictment, does not prevent the exercise of the Supervisor's authority under Section 1טו of the Law. Conversely, an unpaid final fine or financial sanction may prevent the granting of a new permit, under Section 1יד1 of the Law and clause ה.3 of the Procedure, so it is worth settling it.
Section 1טו(a) of the Law allows the Supervisor to refuse the employer's applications, on the ground of the revocation alone, for a period not exceeding three years. Three years is the upper limit, not the default: in the case law, a three-year refusal period was shortened to a year and a half on proportionality grounds, taking into account the severity of the breach, the fact that the information was given to the Authority by the employer itself, and the time that had passed before the decision was issued.
Revocation of the permit is directed at the employer. It has been held that this does not negate the worker's right to apply for a work licence with another patient, although such an application will also be examined in light of the circumstances of the revocation. As a rule, the worker has about 90 days to arrange employment with another employer holding a valid permit, under Section 11(א1) of the Entry into Israel Law. In addition, clause ב.9 of Procedure 9.9.0001 allows the Supervisor to grant temporary approval to continue employment for a period of up to three months, if this is necessary to protect the workers.
A decision of the Supervisor under Section 1טו is challenged by an administrative petition to the District Court sitting as the Court for Administrative Affairs, not by an appeal to the Appeals Tribunal. Clause ד.2 of Procedure 9.9.0001 requires the Authority to state in the decision itself the competent forum and the statutory deadline for filing. The deadlines are short, so you should act as soon as the decision is received and consider, in parallel, a motion for an interim order to freeze its entry into force.