A practical guide to Israel's 2025 procedure for registering international humanitarian NGOs: conditions, grounds for refusal, staff visas, and appeals.
If you manage an international non-governmental humanitarian organisation whose activity is directed mainly at Palestinian residents, or advise such an organisation, the route you knew no longer exists. For years, the status of international staff was regulated through the organisation's registration with the Department of International Relations at the Ministry of Welfare, followed by a recommendation that made it possible to obtain a B/1 residence and work licence from the Population and Immigration Authority. Since October 2023 the Ministry of Welfare has stopped examining such applications, and in December 2024 responsibility was transferred to a different body.
Today, registration is handled by an inter-ministerial team headed by the Director-General of the Ministry for Diaspora Affairs and Combating Antisemitism, under a dedicated Procedure published on 9 March 2025. Registration is not a technical formality: it is a threshold condition for any visa application on behalf of the organisation's foreign employee, subject to a detailed list of grounds for refusal, and its expiry triggers an obligation to remove the organisation's foreign employees from Israel and from the Area.
The statutory basis for the entire arrangement is the Entry into Israel Law, 5712-1952. The former Procedure — Procedure 5.3.0025 (Procedure for Handling the Entry of International Staff of Non-Governmental Humanitarian Organisations into the Territory of the State of Israel), first edition of 1 September 2013 — made the issuance of the licence conditional on two cumulative requirements: that the employing organisation was registered and approved by the Department of International Relations at the Ministry of Welfare, and that a recommendation had been received in respect of the employee from that same department. Accompanying family members received a B/2 licence.
On 9 December 2024 the Government adopted Decision 2542, establishing an inter-ministerial team headed by the Director-General of the Ministry for Diaspora Affairs and Combating Antisemitism. Its members include representatives of the security agencies — among them the National Bureau for Counter Economic Terrorism, the Coordinator of Government Activities in the Territories, and the Israel Security Agency — alongside the Population and Immigration Authority, the Ministry of Foreign Affairs, and the Ministry of Welfare. Responsibility for registration and for issuing recommendations was transferred from the Ministry of Welfare to the team, together with a transitional provision under which existing registrations and recommendations remain in force. Section 2(ט) of the Decision clarifies that it does not detract from the authority of the Population and Immigration Authority under the Entry into Israel Law.
The Procedure sets out a two-stage administrative process. In the first stage, the team examines the organisation's application to be registered as an international non-governmental humanitarian aid organisation whose activity is directed mainly at Palestinian residents, and checks whether any consideration exists that would prevent its registration. In the second stage, individual applications for a positive recommendation regarding a foreign employee are examined, and section 5.2 of the Procedure provides that such an application is to be submitted only after the organisation has been approved.
The practical implication is stark: registration of the organisation is a threshold condition for the examination of any application concerning an employee. Only after a positive recommendation has been obtained does the organisation approach the Population and Immigration Authority for a general B/1 international-organisation residence and work licence — this is how section 3.4 of the Procedure defines the “work licence,” including its renewal — and section 10.2 clarifies that the validity of the recommendation is subject to the Entry into Israel Law. The decision on the licence application therefore remains with the Authority, and the team only builds the factual record and makes a recommendation.
The registration application includes the organisation's particulars, a description of its activities, the names of the organisations with which it works, authorisation for its activity from the Palestinian Authority (unless it operates in the Gaza Strip alone), and more. Section 6.1 of the Procedure provides that the team will discuss only applications submitted in full and in proper form — an incomplete application does not wait in a queue; it simply is not considered.
The most contentious requirement is the one in section 5.1(8): the particulars of the organisation's representative in Israel, and a list of all of the organisation's employees involved in the actual management and implementation of the work plan — including Palestinian employees and the foreign employees in respect of whom a recommendation application will be submitted — stating full names, passport or identity-card numbers, and contact details. European organisations refused to provide this information, arguing that doing so would place them in breach of the GDPR.
The Supreme Court rejected the argument: the requirement is limited to formal identifying data and contact details and does not concern “sensitive information,” and Israel has been granted an “adequacy decision” by the European Commission. The Court further held that the Protection of Privacy Regulations (Provisions Concerning Information Transferred to Israel from the European Economic Area), 5783-2023, exempt in regulation 2(ב)(2) the use of information required to protect state security, to the extent necessary and proportionate. In practice, the Court was told that at least 41 organisations, including 14 from EU member states, had already transferred the information.
Section 7 of the Procedure lists the considerations on the basis of which a registration application or a recommendation application may be refused. These include: denying the existence of the State of Israel as a Jewish and democratic state; incitement to racism; support for the armed struggle of an enemy state or a terrorist organisation against Israel; the organisation's designation as a terrorist organisation, or ties with a designated terrorist organisation; unlawful activity; Holocaust denial; denial of the 7 October massacre; a call for boycott; and active promotion of delegitimisation activity.
The boycott ground is set out in section 7.1(7), and applies to an organisation that publishes, or published in the seven years preceding the application, a knowing public call for the imposition of a boycott on the State of Israel as defined in the Law for Prevention of Damage to the State of Israel through Boycott, 5771-2011, or that has undertaken to participate in such a boycott. The statutory definition speaks of a deliberate refraining from economic, cultural or academic ties with a person or entity “only because of its affiliation with the State of Israel, one of its institutions, or an area under its control,” and the Supreme Court has held that this also covers the boycotting of businesses in settlements in the Judea and Samaria Area. Accordingly, a campaign calling for avoiding trade only with settlements — even where the organisation contends that it is not directed against Israel as a whole — falls within the scope of this ground.
The delegitimisation ground in section 7.1(8) rests on a definition adopted in a decision of the Ministerial Committee on National Security Affairs concerning combating the phenomenon of delegitimisation, under which “criticism of the policy of the Government of Israel, as such, within the bounds of freedom of expression, does not fall within the definition.” Case law has voiced the view that this is a kind of “catch-all ground,” which should be construed narrowly and cautiously and applied only to an organisation that categorically denies Israel's very existence — but this was an obiter remark by a single justice; the author of the leading opinion noted that the matter raises difficulties, and the Court did not decide the question.
Organisations that had been registered with the Ministry of Welfare were required to submit a full application under the new Procedure by 9 September 2025 (sections 3.8 and 10.5 of the Procedure), a deadline that was extended to 31 December 2025. Section 8.4 of the Procedure provides that upon expiry of registration, the organisation must remove its employees from the Judea and Samaria Area, the Gaza Strip, and the State of Israel within 60 days.
The Supreme Court bounded the consequences of this with two clarifications. First, non-registration does not extinguish the organisation's legal personality and does not erase its registration with the Palestinian Authority; it merely deprives the organisation of the sovereign tools of assistance — entry visas to Israel and the ability to transfer aid shipments through border crossings. Second, the Court held — and the State did not dispute this — that the State has no legal basis to prohibit organisations from employing local Palestinian staff within the Authority's territory, or to restrict their movement.
The most significant opportunity to be heard comes before the decision is made. The team notifies the organisation of its recommendation to refuse the application, specifies the publications and the sources on which it relies, and allows the organisation to submit written arguments. Note a risk exposed in the case law: the response letter itself may establish an additional ground for refusal that was not stated in the recommendation, and the right to be heard will be regarded as satisfied so long as the materials underlying that ground had already appeared in the recommendation.
The team's final decision is challenged by way of a petition to the High Court of Justice (HCJ). Two practical lessons emerge from the proceedings to date: do not delay — in one petition the State argued substantial delay (laches); and do not save central arguments for a response to the State's preliminary response, since such a response requires leave of the court. The costs risk is also real: in a petition that was dismissed, costs of NIS 10,000 were awarded.
The route of challenge in the case of an individual employee is different. A refusal or non-renewal of a licence by the Population and Immigration Authority is challenged first by an internal appeal, without delay and no later than 21 days from the date the decision is received (section ג.1 of Procedure 1.6.0001); thereafter by an appeal to the Appeals Tribunal for immigration matters (generally within 30 days, under section 13כד(ב) of the Entry into Israel Law); and its judgment is challenged by an administrative appeal to the District Court within 45 days. A refusal of entry at a border crossing is likewise challenged by way of an appeal, and it may be filed through a lawyer in Israel even after the employee has been returned abroad.
In HCJ 32300-10-24 (3 Mar 2025), a coalition of aid organisations petitioned against the freeze on processing applications since October 2023. The petition was struck out following the adoption of the Government Decision, on the ground that a material change had occurred in the factual and normative basis; no costs were awarded and the parties' arguments were reserved. The lesson: faced with administrative paralysis, the remedy came through a fresh regulatory arrangement.
In HCJ 69668-02-26 (19 May 2026), international aid organisations, together with a coalition of organisations, challenged the information requirement in section 5.1(8) and the consequences of section 8.4. The petitions were dismissed: the team's authority derives from the authority of the Minister of the Interior under sections 6 and 14(א)(1) of the Entry into Israel Law, and the team is a professional body that makes recommendations to the authority vested with power under the statute. Beyond the strict requirements of the law, a 30-day extension was granted to complete a full application. The lesson: the effective battleground is the individual decision.
In HCJ 85895-02-26 (31 Aug 2026), the petition of a Christian humanitarian organisation based in Sweden was dismissed. The team had recommended refusing its registration on the ground of delegitimisation, and after the organisation submitted a response letter — in which it stated that it had taken part in a campaign calling for a boycott of trade supporting the settlements — the decision came to rest on the boycott ground as well. The Court held that the boycott ground was clearly made out, rejected the argument that the right to be heard had been violated, and awarded costs of NIS 10,000.
At the employee level, two appeals illustrate that the entry check is a process separate from the organisation's registration. In Appeal (Tel Aviv) 2168-25 (28 Apr 2026), the appeal of a British citizen connected with the activity of organisations in the Area was dismissed; his entry had been refused at Ben Gurion Airport following questioning and the position of the security agencies regarding his public statements. The decision was found to fall within the zone of reasonableness, and costs of NIS 3,000 were awarded. In Appeal (Jerusalem) 1206-26 (20 Jan 2026), the appeal of a woman who claimed to be a long-standing employee of a humanitarian organisation was dismissed at the threshold; she had been refused entry at the Allenby Crossing on security and public-order grounds — among other things because the stated purpose of her visit remained “extremely vague.” The lesson: document the purpose of travel and the terms of employment in advance and in writing.
Our office guides international organisations and their employees through every stage of this process: building a registration file that will be submitted in full and in proper form and considered on its merits, drafting a response letter to a refusal recommendation grounded in an understanding of the section 7 grounds and how the courts have construed them, handling recommendation applications and visa applications before the Population and Immigration Authority, and representation in an internal appeal, before the Appeals Tribunal, in an administrative appeal, and in a petition to the High Court of Justice. We place particular emphasis on timetables — the deadlines for challenge and the 60-day preparation period — since in this field a short delay can close the door.
No. Section 5.2 of the Procedure provides that an application for a positive recommendation regarding a foreign employee may be submitted only after the organisation that employs them has been approved. Registration of the organisation is a threshold condition for the individual process, and only following a positive recommendation can an application be made to the Population and Immigration Authority for a general B/1 international-organisation licence.
Under Supreme Court case law — yes. The definition of a “boycott of the State of Israel” in the Law for Prevention of Damage to the State of Israel through Boycott, 5771-2011, includes refraining from economic ties because of an affiliation with an area under Israeli control, including businesses in settlements in the Judea and Samaria Area. In a petition decided in 2026, an organisation's argument that this was merely substantive criticism was rejected.
The Supreme Court rejected the argument that this creates a normative trap, among other things because Israel has been granted an adequacy decision by the European Commission and because section 5.1(8) is limited to formal identifying data and contact details. That said, the judgment does not substitute for advice under the law of your own home jurisdiction, and it is advisable to document the legal basis for the transfer before disclosing the information.
Section 8.4 of the Procedure sets a period of 60 days from the expiry of registration for removing employees from the Judea and Samaria Area, the Gaza Strip, and the State of Israel. Expiry of registration does not extinguish the organisation's legal personality, and under the case law the State has no authority to prohibit the employment of local Palestinian staff within the Authority's territory or to restrict their movement.
A decision of the Population and Immigration Authority is challenged by an internal appeal, without delay and no later than 21 days from receipt of the decision, under section ג.1 of Procedure 1.6.0001. Thereafter, an appeal may be filed with the Appeals Tribunal, and its judgment is generally challenged by an administrative appeal to the District Court within 45 days. A refusal of entry at a border crossing is challenged by an appeal to the Appeals Tribunal, even after the employee has been returned abroad.