September 2026: United Nations Updates Database of Companies Operating in Israeli Settlements

Why Is the Database More Important Now?

The database was not without consequence before, but its impact was primarily felt through a limited group of private entities acting independently. For example, in 2021, the Norwegian pension fund KLP excluded 16 Israeli companies from its investment portfolio, including Israel’s largest banks and Bezeq, expressly relying on OHCHR’s 2020 report. In addition, from 2024 to 2025, Norges Bank Investment Management sold its holdings in Paz and Bezeq. To date, however, the consequences of OHCHR’s reports have not materially affected Israeli banks’ core business, and no country has linked inclusion in the database to a legal consequence.

Nevertheless, the database may lead to increased action against Israeli companies.

On September 8, 2026, 11 European countries and Canada announced that they intended either to impose national restrictions on trade in commodities from Israeli settlements or to support equivalent restrictions at the European Union level. These announcements are statements of intent, and import bans do not depend on the database: they are based on the origin of goods rather than the identity of their manufacturer.

By contrast, the UK has announced concrete measures, including plans to establish an authority with power to impose sanctions on individuals and companies that “support, facilitate, or generate profit” from activities connected with Israeli settlements. According to reports, the relevant UK legislation is expected to enter into force within six to nine months. Under the UK Sanctions and Anti-Money Laundering Act 2018, the threshold for imposing sanctions is “reasonable grounds to suspect,” which is lower than OHCHR’s “reasonable grounds to believe” threshold. An OHCHR finding could therefore serve as evidentiary material that easily meets the UK standard.

This does not mean that the database has become a sanctions list. The UK has not stated that it will use the database and has emphasized its commitment to continuing trade with Israel within the Green Line. Sanctions against a major Israeli bank would be a dramatic measure and are not expected imminently. Risk is also unevenly distributed: companies that attract headlines are not necessarily the most exposed. Companies whose core business is in Israeli settlements, including those in the construction, real estate, and infrastructure sectors, face greater exposure than large national companies whose settlement-related activities are marginal.

In the short term, pressure is likely to arise primarily through market channels. European banks and their counterparties often seek to reduce exposure before legislation takes effect. OHCHR’s database is incorporated into commercial screening tools. As a result, automated screening by foreign suppliers or banks may identify “matches” involving Israeli companies, including companies that are not themselves listed but are affiliated with a listed company.

Significant repercussions may also arise from the European Union, particularly under the Corporate Sustainability Due Diligence Directive (CSDDD). The CSDDD requires companies within its scope to identify human rights and environmental impacts in their own operations and throughout their value chains, particularly among direct business partners, and to take steps to prevent or end adverse impacts, including through contractual obligations imposed on partners. The CSDDD will apply directly only to very large companies, with phased implementation beginning in July 2029. Israeli companies may nevertheless be indirectly affected through contractual requirements and due-diligence questionnaires from major European customers and business partners. Comparable requirements already exist under national legislation, including in Germany and France.

Table 2: Exposure Profiles

Can Companies Be Removed from the Database?

OHCHR does not proactively review companies already included in the database. Companies may submit applications for review, supported by new and reliable information. If OHCHR finds reasonable grounds to believe that a company has ceased its relevant involvement and that inclusion is no longer warranted, it transfers the company to the list of companies no longer involved. This year, eight applications were submitted and five companies were removed from the database. Any company may also submit a response and request that it be published on the database’s website. Six companies have done so.

Removal from the database is not necessarily permanent. Hadiklaim – Israel Date Growers Cooperative Ltd. was removed in 2025 but reinstated this year. In 2021, Energix Renewable Energies sold its interest in a photovoltaic facility in the West Bank and announced that it no longer operated there, yet it remains listed in the 2026 update. An application for removal must demonstrate substantive and ongoing changes in activities, and OHCHR assesses new activities before each update.

Companies seeking removal from the database should first assess Israel’s Anti-Boycott Law, which may create two distinct categories of risk.

The first risk is administrative. The Minister of Finance is authorized to deny companies benefits and to restrict their participation in public tenders if they “committed to take part in a boycott against Israel,” and an application to the OHCHR could be interpreted as such a commitment.

The second risk is potential civil liability. The Anti-Boycott Law provides that calling for a boycott against Israel is a civil tort, and companies found liable may be ordered to pay damages. Ceasing activities involving companies that operate in Israeli settlements is not, in itself, equivalent to calling for a boycott. However, a public response posted on the database’s website, a press release, or a stock exchange filing may, if not carefully drafted, be construed as calling for a boycott. The risks can be mitigated through the structure of a removal process and careful wording of inquiries and responses, but these steps should be reviewed in advance. Companies that also operate in the United States should examine applicable US anti-boycott laws in the jurisdictions in which they operate.

What to Expect

Resolution 53/25 requires annual updates. Based on practice over the past two years, the next update is expected in September 2027. Approximately 255 companies identified during the Human Rights Council’s 2024 process have yet to be reviewed. OHCHR has stated that it continues to analyze the nature of companies’ involvement and may adopt more stringent classifications, including “causation.” Companies should also monitor the final wording of UK legislation, the measures that other signatory countries ultimately adopt, and whether the European Union introduces its own restrictions.

What Should Companies Do?

1. Check whether the company, its subsidiaries, parent companies, or material counterparties are listed in the database. The review should also cover prior corporate and trade names. The report’s appendix identifies former names of several companies, including Paz, Re/Max, and Yes.
2. Compare the company’s activities against the exposure profiles in Table 2 and assess the relevant channels of exposure.
3. Companies included in the database should decide whether to submit a public response or an application for review. Before doing so, they should assess the Israeli Anti-Boycott Law and applicable US law.
4. Prepare a standard response for inquiries from banks, investors, and foreign customers that explains the database’s legal status and the company’s position.

These measures do not eliminate risk, but they enable companies to provide informed responses and avoid hasty, panicked action that may create exposure in the opposite direction. We are available to assess your company’s exposure and develop an appropriate response.

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Prof. Amichai Cohen, the firm’s international law expert, is available to answer any questions arising from this article.