Employing a Palestinian worker needs two permits: the employer's employment permit and the worker's entry permit. A practical guide to conditions and appeals.
If you are a contractor, a farmer, a hotel owner, or a factory owner employing Palestinian workers — or if you are a worker whose work permit was not renewed or was revoked — the basic rule is that one permit is not enough. Employing a Palestinian worker in Israel requires two separate permits from two different authorities: the employment permit (employer's), which the employer receives from the Population and Immigration Authority, and the entry permit for work (issued by the military commander), which the worker obtains through the Civil Administration. One does not replace the other, and the gap between them is a common source of fines and permit revocations.
A note on currentness: since October 2023, the entry policy for Palestinian workers and the sector-by-sector quotas have changed repeatedly. This guide describes the fixed legal framework — the statute and the sector procedures as published — not the state of the quotas on the day you are reading it. Before taking any practical step, verify the current picture with the Employers' Service Bureau and the Civil Administration.
Section 1יג of the Foreign Workers Law, 5751-1991 provides that no person may take on a foreign worker unless the Commissioner has granted a permit to employ that worker, and only in accordance with the permit's conditions; the Commissioner is the Director-General of the Population and Immigration Authority. Clause ב.1 of Procedure 9.1.1001 (the Procedure for Regulating the Employment of Palestinian Workers in Israel in the Construction Sector, 9th edition, updated 3.4.2025) extends this regime also to persons whose permanent residence is in Judea and Samaria or in Gaza and who are not registered in Israel's population registry.
Clause ב.4 of the same Procedure, and the parallel Clause ב.4 of Procedure 9.1.3008 (the agriculture sector, 7th edition, updated 2.12.2025), stress that the employment permit alone is not enough, because the worker also needs an entry permit for work (issued by the military commander), granted to residents of Judea and Samaria through the Civil Administration under Section 8(2) of the Citizenship and Entry into Israel Law (Temporary Order), 5782-2022. Employment permits are subject to the maximum quotas set by the Directors-General Committee on Foreign Workers, and any change to a quota is made solely by that committee's decision (ב.2–ב.3).
In the construction sector, Clause ה.1 of Procedure 9.1.1001 sets three threshold conditions: the contractor must be registered in the Contractors' Register and hold a valid licence — throughout the entire permit period; must not be a manpower contractor or a manpower broker; and must have opened an employer file with the Employers' Service Bureau. Removal from the register or suspension of the licence leads to a hearing, and, following it, to revocation or restriction of the permit.
In agriculture, a recommendation from the Ministry of Agriculture is required, though it does not diminish the Authority's own discretion (ה.1 of Procedure 9.1.3008). A new employer seeking to employ more than ten workers must deposit a bank guarantee for a six-month trial period — NIS 1,100 for each worker from the eleventh onward, multiplied by six months (ה.6); even a request by an active employer to increase its quota by an exceptional rate may be made conditional on a guarantee (ה.7). In the hospitality sector (Procedure 9.1.3013), the permit is valid until the end of the calendar year in which it was granted (ד.16). Procedure 9.1.3006 applies to factories relocated from Judea and Samaria.
In construction, the permit is a general one that does not specify a number of workers, pursuant to Government Decision 2174 of 18.12.2016. The quota is embedded in the entry permits issued by the Civil Administration, and it is therefore treated as belonging to the workers, who are entitled to move between employers within the sector (ב.9–ב.10).
The employment permit by itself does not authorize employment. The employer must give it effect by submitting an application for an entry permit for work for each worker (Clause ח.1). Clause ח.3 provides that the decision to approve or reject such an application, the setting of special conditions in the permit, and the setting of threshold conditions of age and family status, are within the sole authority of the Civil Administration, and the permit's validity period is set at its discretion (ח.4).
The application is submitted to the Employers' Service Bureau together with the worker's bank account details, and only after the employer has verified that the worker holds a valid magnetic card (ח.5–ח.7). The Bureau will reject an application if the employer owes debts to the Bureau or to the Ministry of Labour, or if the worker does not meet the updated criteria of the security establishment (ח.8); only a proper application is forwarded to the Civil Administration, and an approved permit is sent to the employer by email (ח.9–ח.10).
Two practical points: the work permit is valid only for the sector in which it was issued and may not be used for entry for other purposes (ח.13); and a worker who has finished working in the construction sector keeps their place in the quota for 60 days, during which their entry is permitted only under a job-search permit — and it is expressly forbidden to employ them under such a permit (ב.11). The employer must immediately report and request the cancellation of the permit of a worker who has resigned, been dismissed, or been absent for seven consecutive days (ח.17).
Clause ט.2 of Procedure 9.1.1001 provides that the protective labour law applicable to an Israeli employee — including collective agreements, extension orders, and occupational safety law — applies in full to a Palestinian worker as well. Failure to pay the sectoral minimum wage, failure to pay for overtime, and failure to keep a record of working and rest hours constitute a breach of the permit's conditions and an offence under the law.
Since 1.1.2023, wages must be paid solely by bank transfer to the worker's account held in the Palestinian Authority (ט.3), and, from the January 2025 pay period onward, employers themselves generate the payroll and calculate its components — pension and severance pay, income tax, National Insurance, the equalization levy, and the health stamp (ט.11) — and issue the payslips (ט.18). Truthful monthly reporting is the employer's responsibility, and false reporting or failure to transfer payments is defined in the Procedure as a serious breach of the permit's conditions (ט.9).
Additional obligations: direct employment only, without transferring the worker and without employment through a manpower contractor or a service contractor (ט.6); at least a full-time position (ט.8); and collecting the workers from the crossing and transporting them at the employer's expense (ח.14–ח.15). Under Section 1כ of the Law, the State is not liable to the worker for amounts that were not collected from the employer, and the worker may sue for them in the Labour Court (ט.19).
A breach of the Procedure's provisions, which form an inseparable part of the employment permit, may lead to revocation of the permit under Section 1טו of the Foreign Workers Law, to administrative fines, or to an indictment (ב.13). Section 1טו(א) authorizes the Commissioner, after giving the employer an opportunity to present arguments, to revoke the permit and refuse the employer's applications for a period of up to three years; Section 1טו(א2) adds a similar power against anyone who has committed a serious offence as defined in the Law. The enforcement procedure is set out in Procedure 9.9.0001 (2nd edition, 3.3.2022).
Barriers already operate at the application stage: opening an employer file or a permit application will not be approved for a person who owes debts to the Bureau over unpaid wages to Palestinian workers, or who has an unsettled fine or financial sanction (ו.12 of the construction Procedure; ה.8 of the agriculture Procedure). When the applicant is a family member of such an employer, the suspicion that the permit is meant to let the debtor employ workers indirectly is examined, and a written hearing is held before a decision is made (ו.13; ד.14 of the hospitality Procedure).
For the worker, the consequences are no less severe. Staying in Israel without a valid entry permit exposes the worker to criminal proceedings under the Entry into Israel Law, 5712-1952, and, in parallel, to an administrative process: a hearing before the Border Control Officer in Charge, a detention order and a removal order, and being brought before the Detention Review Tribunal under Section 13יד(א). Grounds for release are examined under Section 13ו(א) — among them a good-faith error or malfunction, voluntary departure from Israel, or special humanitarian reasons.
A decision rejecting a permit application must be reasoned in writing and must state that an internal appeal may be filed against it, without delay and no later than 21 days; the appeal is examined by the Director of the Employers' Service Division. If the appeal is rejected, a reasoned refusal notice will be sent, stating the option of filing an administrative petition with the District Court sitting as the Court for Administrative Affairs in Jerusalem, without delay and no later than 45 days (Clause ו.9 of Procedure 9.1.1001).
The Supreme Court noted, in an observation beyond what was strictly necessary, that an employer may have an alternative remedy before the Court for Administrative Affairs under Item 12(4) of the First Schedule to the Courts for Administrative Affairs Law, 5760-2000, and that a petition should not be entertained before a final and concrete decision has been reached and before proceedings have been exhausted. In detention proceedings, the route is different: a decision of the Detention Review Tribunal is appealed to the District Court sitting as the Court for Administrative Affairs, within 45 days. Where a decision is about to cause irreversible harm, an interim order may be requested.
In Adm. Petition (Jerusalem) 21062-01-22 (15 Feb 2023), the court considered a company that held a permit to employ one Palestinian worker, whose owner had been convicted, on his own admission, of unlawfully employing a foreign worker. The Commissioner revoked the permit and refused to grant the company a permit for three years. The court held that employing a worker without a permit is an offence committed against the worker as well, since it undermines the reporting and payment system designed to protect him; however, three years was found disproportionate — among other things because the Authority learned of the employment from the employer himself and about a year and a half had passed before the decision — and the period was shortened to a year and a half. The appeal was dismissed in Adm. Appeal (Supreme Court) 3109/23 (22 Jan 2024). The lesson is twofold: the sanction is subject to review for proportionality, but letters in which an employer admits to employing without a permit serve as evidence against him.
In HCJ 1049/24 (8 Feb 2024), agricultural companies petitioned following the ban on the entry of Palestinian workers after the outbreak of the war, arguing that the alternative foreign-worker quotas were insufficient for the harvest season. The petition was dismissed in limine: it was premature, since no concrete decision concerning the petitioners had been pointed to, and proceedings had not been exhausted. For an employer harmed by a change of policy, this is the central signpost: without a concrete application and a concrete decision, there is nothing to attack.
Similarly, in HCJ 4285/24 (18 Jan 2026), a petition against restrictions on the entry of Palestinian farmers into the Seam Zone imposed after October 2023 was dismissed, on the ground that a judicial forum will not readily intervene in a security-based exercise of discretion; a request for a further hearing was also dismissed (Further HCJ Hearing 82761-01-26, 17 Mar 2026). It was nonetheless clarified that a person individually harmed may seek redress through the appropriate channel.
And from the worker's side: in a Detention Review Tribunal decision in case 1181-07-26 (16 Jul 2026), the case concerned a detainee who had entered Israel in September 2023 under a lawful entry permit that expired a few weeks later. He remained in Israel, was convicted on his own admission of the offence of unlawful entry or residence, and, once his prison term ended, was transferred to the administrative track. The Tribunal upheld the detention order, holding that it had not been proven that the stay was rooted in a good-faith error and that no special humanitarian reasons had been found. The expiry of a permit, then, is not merely the end of employment.
Our office guides employers and workers through every stage of the permit regime: applying for an employment permit and opening an employer file, responding to hearing letters before a permit is revoked or restricted, filing an internal appeal with the Employers' Service Division, administrative petitions and applications for interim relief, and representing workers in detention and removal proceedings. We examine every case against the language of the Law and of the relevant sector Procedure, insist on documentation from the very start of the process, and present a complete factual foundation — without promising results, and with the recognition that entry policy keeps changing and requires renewed review each time.
No. Clause ב.4 of Procedure 9.1.1001 and of Procedure 9.1.3008 stress that, in addition to the employer's employment permit, the worker also needs an entry permit for work (issued by the military commander), granted through the Civil Administration. Employing a worker who does not hold a work permit valid for the sector constitutes an offence under the Foreign Workers Law and a breach of the permit's conditions. Both permits must be valid at the same time.
Under Clause ב.11 of Procedure 9.1.1001, the worker's work permit is not removed from the sector quota for 60 days, during which the worker's entry into Israel is permitted only through a job-search permit issued by the Civil Administration. It is expressly forbidden to employ a worker who holds only a job-search permit. If the worker is not taken on by a new employer within 60 days, the permit is removed from the quota.
Since 1.1.2023, wages must be paid solely by bank transfer to the worker's bank account held in the Palestinian Authority (Clause ט.3 of Procedure 9.1.1001). From the January 2025 pay period onward, the employer itself generates the payroll, calculates the pension, severance pay, income tax, National Insurance, the equalization levy, and the health stamp, and issues the payslips. Payment other than by bank transfer constitutes an offence under the Foreign Workers Law and a breach of the permit's conditions.
Section 1טו(א) of the Foreign Workers Law allows the Commissioner, after a hearing, to revoke the permit and refuse the employer's applications for a period of up to three years; in cases of a "serious offence" there is a parallel power under Section 1טו(א2). In addition, administrative fines may be imposed or an indictment filed. The case law has held that the sanction is subject to the duty of proportionality, and in one case the refusal period was shortened from three years to a year and a half, a ruling that was upheld on appeal.
Procedure 9.1.1001 provides that a decision of the Director of the Employers' Service Bureau may be challenged by a written internal appeal, without delay and no later than 21 days, examined by the Director of the Employers' Service Division. If the appeal is rejected, an administrative petition may be filed with the District Court sitting as the Court for Administrative Affairs in Jerusalem, without delay and no later than 45 days. It is advisable to act as early as possible, since a claim of delay may be raised even within the stated time limits.