Abstract

On 9 March 2025, amid the humanitarian crisis in Gaza, Israel issued new registration rules for international humanitarian organizations assisting Palestinians. The rules implemented a December 2024 government decision assigning registration to an interministerial team led by the Ministry of Diaspora Affairs and Combating Antisemitism. They required organizations to disclose personnel information, including details of Palestinian employees, and introduced grounds for refusal concerning organizational conduct, including boycott activity. Registration was also linked to recommendations for foreign employees and access to certain State-controlled facilities, allowing an administrative refusal to interrupt programmes dependent on those arrangements. This article examines the occupation-law obligations engaged by such restrictions through two 2026 judgments of Israel’s High Court of Justice, which upheld the personnel-disclosure requirement and a boycott-based refusal. It reads the judgments against the Fourth Geneva Convention, drawing on the International Committee of the Red Cross (ICRC)’s 2025 Commentary and the International Court of Justice’s advisory opinion of 22 October 2025 to establish the scope of the relevant protections. The analysis distinguishes interference with a qualifying relief society’s humanitarian activities under Article 63 from the occupying Power’s obligation under Article 59 to agree to and facilitate relief for an inadequately supplied population. It argues that registration controls remain subject to the conditions protecting the organization’s work, while exclusion of a provider leaves the duty to facilitate sufficient relief in place. Where refusal interrupts assistance, compliance must therefore be assessed through evidence of the work affected, the population’s continuing needs, and the practical capacity of other arrangements to meet them.

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