The clock is ticking on a large part of the humanitarian response sustaining civilians in the occupied Palestinian territory.
Thirty-seven international aid organisations have been ordered by Israeli authorities to cease operations in the occupied Palestinian territory by the end of February under revised Israeli registration rules. With efforts to force closures imminent, a group of leading humanitarian organisations have taken the unprecedented step of jointly petitioning the Israeli High Court to suspend the measures before irreparable harm is done to civilians who rely on their assistance.
On 30 December 2025, the affected organisations were formally notified that their Israeli registrations would expire the following day and that they would have 60 days to wind down activities in Gaza and the West Bank, including East Jerusalem. The notification letter stated that the decision could only be overturned if organisations completed the full registration process, with which they cannot legally or ethically comply.
Efforts to force closures could begin as early as 28 February 2026. The effect would be immediate, extending well beyond individual organisations to the wider humanitarian system. In Gaza, families remain dependent on external assistance amid continuing restrictions on aid entry and renewed strikes in densely populated areas. In the West Bank, including East Jerusalem, military incursions, demolitions, displacement, settlement expansion and settler violence are driving rising humanitarian needs.
Palestinian Authority registration provides the lawful basis for international NGOs to operate in Palestinian territory. Under the Fourth Geneva Convention, an occupying power must facilitate relief for civilians under its control. Conditioning humanitarian presence on sweeping administrative demands, including the transfer of comprehensive national staff lists, alongside vague and politicised grounds for denial, risks disrupting life-saving services and eroding the obligation to ensure civilian welfare under occupation.
The demand to transfer personal data raises acute security and legal risks. It exposes national staff to potential retaliation and undermines established data protection and confidentiality safeguards. For European organisations in particular, compliance would create serious legal and contractual liabilities. More broadly, such requirements set a precedent that could chill principled humanitarian engagement in highly politicised contexts.
International NGOs have proposed practical alternatives, including independent sanctions screening and donor-audited vetting systems, that preserve both compliance and staff protection without disclosing personal data. No substantive response has been provided. Enforcement has meanwhile begun in practice, including blocked supplies and denial of visas and access for foreign staff.
Alongside UN agencies and Palestinian partners,
international NGOs support or implement the delivery of more than half of all food assistance in Gaza, 60 per cent of field hospitals’ operations, nearly three quarters of shelter and non-food item activities, all inpatient treatment for children suffering severe acute malnutrition and 30 per cent of emergency education services, in addition to funding over half of explosive hazard clearance.
The petition seeks an urgent Interim Injunction to suspend expiry of registrations and prevent further enforcement pending judicial review. The petitioning organisations contend that these administrative measures constitute an effort to curtail established humanitarian operations in a manner incompatible with the obligations of an occupying power under international humanitarian law.
Governments must act urgently to prevent implementation of these measures and to ensure that humanitarian relief remains principled, independent, and unhindered. If these measures take effect, aid will be impeded not because needs have eased, but because it has been rendered optional, conditional, or politicised. At a moment when civilians depend on assistance to survive, that outcome would carry immediate and irreversible human consequences.
Petitioners and supporting organizations
1. All We Can
2. ActionAid Australia
3. Alianza Por La Solidaridad
4. Association of International Development Agencies (AIDA)
5. Bystanders No More
6. CADUS e.V.
7. Choose Love
8. Christian Aid
9. Churches for Middle East Peace
10. DanChurchAid
11. Danish Refugee Council
12. Diakonia, Sweden
13. Humanity & Inclusion – Handicap International
14. medico international
15. Middle East Children’s Alliance
16. Movimiento por la Paz, Desarme y Libertad – MPDL
17. Muslim Aid
18. Nonviolent Peaceforce
19. Norwegian Church Aid
20. Norwegian Refugee Council
21. Oxfam
22. Pax Christi International
23. Première Urgence Internationale (PUI)
24. Pro Peace
25. Refugees International
26. Start Network
27. Tearfund
28. Terre des hommes Italy
29. Terre des hommes Lausanne (Tdh)
30. United Against Inhumanity
31. Weltfriedensdienst e.V. (WFD; World Peace Service)
Notes:
Executive Summary – Joint Petition against the Inter-Ministerial Team:
1. Introduction
This Petition is filed by 17 leading international humanitarian aid organizations (INGOs) and the Association of International Development Agencies (AIDA) which form the critical infrastructure for providing medical services, food, and water to the civilian population in the West Bank and Gaza. The Petitioners challenge the Respondents’ December 2025 decision, which orders the “termination of their activities” due to their refusal to provide personal contact details (Nominal Lists) of thousands of local employees. The Petition presents an unprecedented “legal deadlock” in which the demands of the Israeli administration directly contradict international privacy laws and the fundamental principles of humanitarian neutrality.
2. Urgent Request for an Interim Injunction
The Petitioners seek an interim Injunction to preserve the status quo and prevent the expiration of their registration, the deportation of foreign staff and cessation of all activities until a final ruling is reached. It is argued that the “Balance of Convenience” clearly favors the Petitioners: while the Respondents will suffer no harm by maintaining the current situation, the cessation of the organizations’ activities will lead to a humanitarian collapse and irreparable harm to the right to life and health of hundreds of thousands of individuals in need.
3. Legal Arguments
A. Breach of the Inter-Ministerial Team’s Basic Obligations as an Administrative Authority
The Respondents’ conduct is tainted by administrative laches (undue delay) and a lack of good faith. The Respondents delayed their response to registration requests for many months while creating a false representation that the applications were under review. These draconian requirements were imposed without granting a Right to be Heard and without meaningful dialogue, violating the heightened duty of fairness applicable to the authority.
B. The Requirement for Employees’ Personal Details (Nominal Lists)
– B.1 GDPR Regulation and the “Adequacy” Issue: The Petitioners, who are bound by European law, demonstrate that transferring employee data from the Occupied Palestinian Territory (oPt) to Israeli security authorities constitutes a criminal and administrative offense. Since the European Union’s “Adequacy” decision regarding Israel does not apply to the territories, the organizations are exposed to heavy fines and tort claims. The Petition relies on the Schrems II precedent of the Court of Justice of the European Union, which prohibits data transfer to jurisdictions lacking independent judicial oversight over security agencies.
– B.2 The Demand for Employee Details and Violation of International Law: The requirement to provide personal phone numbers and contact details of the entire staff violates the principle of “Data Minimization” and endangers the personal safety of the employees. Turning humanitarian organizations into an information-gathering arm for a party to the conflict stands in total contradiction to the principle of neutrality.
C. The Decision for a Sweeping Cessation of Activity is Void Due to Illegality
– C.1 Decision Lacking Authority (Ultra Vires): The Team’s government mandate is limited to technical registration and visas. Assuming the authority to order the termination of an international organization’s activities is an extreme deviation from authority without an explicit legal source.
– C.2 Deviation from Israel’s Sovereignty (Oslo Accords): Pursuant to the Civil Annex of the Oslo Accords, the authority to register and manage NGOs operating in Palestinian Authority territories was transferred to the Palestinians. Israel lacks the authority to order the closure of these entities.
D. Regulation Article 8.4 – Voidness due to Lack of Authority and Breach of International LawThe Petitioners challenge the article in the regulation that allows for the suspension of registration based on vague “security considerations” without a duty of specification or reasoning.
– D.1 Applicability of Article 63 of the Fourth Geneva Convention: This article imposes an obligation on the Occupying Power to allow relief societies to continue their work. The Petition relies on expert legal opinions establishing that this provision fully applies to International NGOs (INGOs) performing essential humanitarian functions.
E. Extreme Unreasonableness and Lack of Proportionality
The decision fails the “Proportionality Stricto Sensu” test: the limited administrative-security benefit of collecting phone numbers is dwarfed by the catastrophic human damage caused by withholding aid from the population. The Respondents refused to consider “less restrictive means,” such as cross-referencing names against public global terror lists.
F. Violation of Israel’s Obligations to Facilitate Humanitarian Aid
As an Occupying Power, Israel bears positive obligations (Articles 55, 56, and 59 of the Convention) to ensure the supply of food and medical services. Arbitrary and bureaucratic interference with organizations fulfilling these duties constitutes a blatant violation of international law and the directives of the International Court of Justice (ICJ).
