Legal notice
This is a free information tool operated by an AI model, with no accountant or lawyer involved, reviewing it or approving it. It produces checklists, gap lists and summaries of deadlines and amounts for internal organisation only, for the amuta's own officers to review and adopt themselves. It is not legal advice and not accounting advice.
It does not produce, and must not be presented as producing, an audited financial statement, an auditor's opinion, or any other work product reserved to a licensed accountant under the Accountants Law. Auditing a financial report is reserved to a certified public accountant (roeh cheshbon). Drafting or amending a תקנון, and any legal opinion, belong to a lawyer: the Bar Association Law reserves those whether or not a fee is charged, so the fact that this tool is free is not a defence. It drafts no legal instrument, and any text it does produce is an automatic draft for personal organisation only, not a document prepared by a lawyer or an accountant.
The tool may err, omit data, or present a wrong conclusion, and it is not a substitute for advice that takes account of the particular circumstances and needs of each person. Responsibility for filing and payment is yours, the binding determination belongs to the Registrar of Associations and to the Tax Authority as the case may be, and representation before the Tax Authority is reserved to those entitled to it by law.
Figures in this skill carry a year. Israeli thresholds are index-linked and are re-gazetted annually. Confirm the operative figure for the year you are filing before relying on it.
Problem
An amuta loses its Certificate of Proper Management for reasons that have nothing to do with how well it runs its programmes: it filed the wrong year's reports, it never appointed the organ its turnover band requires, or it paid the wrong fee tier and cannot get the difference back. The rules sit across the Associations Law, a Registrar circular, a fee regulation and a Tax Authority execution instruction, and the public guides that summarise them are wrong often enough to be dangerous. Without the certificate the amuta cannot receive state support, cannot apply to most foundations, and its donors cannot claim their tax credit.
Instructions
Work through the steps in order. Steps 1 to 3 establish which rules apply; steps 4 to 7 produce the deliverables. Do not skip step 2: the wrong reporting year is the commonest way to build a package that cannot be filed.
Step 1: Identify the entity and read its registry position
Ask for the amuta's registration number (מספר עמותה, 9 digits starting 58) or its exact name. A חל"צ has a company number starting 51 and follows a different track, see step 10.
If the israel-amutot MCP is available, read the entity's current position rather than asking the
user to recall it:
| Question | Tool |
|---|---|
| Does the amuta exist and what is its status | search_amuta, get_amuta_details |
| Does it hold a current certificate, and for which year | check_management_certificate |
| What turnover did it last report | get_financial_info |
| Has it received foreign political-entity donations | search_foreign_donations |
Treat registry figures as the amuta's last reported position, not as today's truth. The turnover that decides this year's duties is the turnover of the year being reported.
If the MCP is unavailable, ask the user for the status, the last certificate year and the turnover, and say plainly that you are relying on their figures.
Step 2: Fix the reporting year (the X minus 2 rule)
A certificate for year X is granted against the annual reports for year X minus 2.
| Certificate sought | Annual reports required | Those reports fell due |
|---|---|---|
| 2026 | 2024 | 30 June 2025 |
| 2027 | 2025 | 30 June 2026 |
| 2028 | 2026 | 30 June 2027 |
State the mapping back to the user explicitly before going further. Users almost always assume the certificate year and the report year are the same, and then prepare the wrong year's documents.
The statutory deadline is section 36(ד): the financial report is filed no later than 30 June of the year following the end of the report period, signed by two board members. The same section expressly lets the Registrar extend that date, which is how the emergency extensions are granted.
Two hard limits decide whether this cycle is open at all. Check them before building anything.
- The one-year bar. The Registrar does not process a certificate request whose accompanying documents were filed more than a year late, meaning after 30 June of the year the certificate is sought for. Past that point the cycle is closed and no amount of remediation reopens it.
- Ninety days is a separate cliff. Under s.59 an amuta is deemed to have ceased operating if it does not pay a fee within ninety days of the last date set for it, or does not file the financial report within ninety days of the s.36 date. The Registrar may then strike it off, applying s.368 of the Companies Ordinance. Late filing is not only a certificate problem.
Extensions go to ACCOUNTANTS, not to amutot. They are issued as filing quotas. Under the arrangement published on 19 May 2026, for 2025 reports and the 2027 certificate, a participating accountant may file 20 percent of client reports by 31.7.2026, 45 percent cumulatively by 31.8.2026, 70 percent cumulatively by 4.10.2026, and 100 percent cumulatively by 1.11.2026. Three consequences the amuta must understand:
- An accountant who did not send the client list to the Registrar by 31.7.2026 is not in the arrangement at all, so their clients get no extension.
- Missing the quota counts as the amuta's failure to comply, not the accountant's.
- A request filed after 1.11.2026 is handled subject to workload, and a certificate runs from the date it is signed, so a full calendar year cannot be guaranteed.
Ask which accountant files for the amuta and whether that accountant joined the arrangement. Then read the Registrar's news page for the arrangement governing the cycle in front of you: these dates are re-issued annually and the ones above are specific to the 2027 cycle.
Work back from the quota date. Nothing can be uploaded until the general assembly has approved the financial report, and s.36(א) requires the report to reach the audit committee or auditing body at least two weeks before that assembly. The order is: the accountant's sign-off where there is an audit, the report to the committee at least two weeks ahead, the assembly, then the upload. Ask which quota date the accountant has assigned this amuta's report to and count back from it.
Step 3: Band the amuta by turnover
Five independent bands key off turnover. They are cumulative, and they are not the same number, so work through all five rather than assuming one threshold governs everything.
| Band | Threshold | Consequence | Source |
|---|---|---|---|
| Organs | any turnover, including none | general assembly, board, and audit committee | s.19(א) |
| Filing exemption | at or below 500,000 NIS | need not FILE the financial report with the Registrar, though it is still prepared; the verbal report is still filed | Forms Regulations, reg. 7(ה)(2) |
| Bookkeeping | above 750,000 NIS, measured on the previous year's receipts | double-entry books instead of a receipts-and-payments book | Second Schedule |
| Audit | above 1,380,630 NIS (the 2026 amount), see point 2 for the 2024 and 2025 reports | must appoint a certified public accountant (רו"ח), and the financial report must reach the general assembly audited | s.19(ג)(1), s.37(א) |
| Internal audit | above 10,000,000 NIS | must additionally appoint an internal auditor (מבקר פנימי) | s.30א |
Four things to get right here:
- The audit threshold is index-linked; the bookkeeping threshold is not. Both descend from a 750,000 NIS figure, but only s.19(ג) carries the indexation clause in s.19(ג)(2). Never reuse the audit figure as the bookkeeping figure. "מחזור" in the Second Schedule is the receipts of the last year that passed, so the books kept during a year follow the previous year's turnover. If the two years fall on opposite sides of 750,000 NIS, flag it and confirm with the accountant.
- The audit figure is not settled for the 2024 and 2025 reports. s.19(ג)(2) requires the amount to be published every February, but after the 2014 notice (1,172,933 NIS) the next one is the 2026 notice (1,380,630 NIS), which says it takes account of the updates for 2014 to 2025. No amount was gazetted for 2015 to 2025. Nor does the statute say plainly whether a year's turnover is measured against that year's amount or against the amount for the year in which it is tested, since "מחזור" means the receipts of the last year that passed. So, for the 2024 and 2025 reports: above 1,380,630 NIS an audit is required on every reading, and at or below 1,172,933 NIS (the 2014 figure, taken from Wikisource's annotated text of the law) no reading requires one. In between, say that the point is unsettled, state that the conservative course is to appoint an accountant, and have the amuta confirm with its accountant or the Registrar. Never tell an amuta in that zone flatly that it needs no auditor. For the 2026 reports, above 1,380,630 NIS the audit is required unless a 2027 notice turns out to govern and exceeds the turnover; for other years, check for a newer notice before reusing either figure.
- Every amuta prepares a balance sheet (מאזן). s.36(א) requires a balance sheet and a statement of income and expenditure from every amuta regardless of size. It is the audit that is banded, not the balance sheet. A small amuta that concludes it need not prepare accounts has misread this. Preparing is not filing, though: at or below 500,000 NIS turnover the amuta is exempt from FILING the financial report under s.36(ד) (Forms Regulations, reg. 7(ה)(2)). The report still goes to the audit committee and the general assembly, the verbal report is still filed, and s.38(א)(3) still refers to the report alongside the assembly protocol. Have the amuta confirm with the Registrar whether this cycle's certificate request asks for it, and expect funders to.
- A A body that audits is not a turnover band. Under s.19(ב) the general assembly may resolve to appoint an accountant or a Registrar-approved body instead of the audit committee. That is an election, available at any size, not something a threshold forces.
Note also s.37(ב): the Registrar may order an audit even for an amuta below the threshold, on the audit committee's request, on the request of a tenth of the members, or on the Registrar's own initiative. Below-threshold is therefore not a guarantee.
Existence is not enough, check composition. The Registrar's proper-management questionnaire screens the organs for family proximity, and a small amuta is the population most likely to fail, because a small board is often a family board. Ask whether there is a majority of relatives among the board members, a majority of relatives among the authorised signatories, or salary recipients who are relatives of an audit committee member. An audit committee that is two siblings is a defect, not a committee. Report it as a gap even though the organ formally exists. This is a substantive refusal ground, as distinct from the paperwork grounds, and it is the one an agent will miss if it only checks that the three organs are named.
The Act adds hard disqualifications. Nobody may sit on the board and on the audit committee or auditing body at the same time (s.32). Under s.33(א) neither organ may include a non-member of the amuta, a person who provides it with paid services other than as a board or committee member (typically a salaried director or coordinator), a minor, a person declared incompetent or bankrupt, a person convicted of the listed offences or of another offence the Registrar deems disqualifying, or a corporation (though a member corporation's representative may sit on the board). A paid service provider may not act as the auditing body (s.33(ב)). Board members may be paid only under a general-assembly resolution, within the limits set under s.34א (s.26א), and any direct or indirect distribution of profits to members is prohibited (s.34ג). On 14 June 2026 the Registrar announced targeted supervision of family ties, citing the guideline that relatives may make up no more than 10% of employees or 10% of payroll, defining a relative broadly (step-relations included), and inviting amutot to correct before it begins.
Step 4: Build the filing checklist
The annual package is four documents. Produce them as a checklist with a status per document, not as prose.
| # | Document | Notes |
|---|---|---|
| 1 | financial report (דוח כספי) | balance sheet plus income and expenditure, per the Second Schedule list. Signed by two board members. Audited if step 3 put the amuta over the audit threshold. At or below 500,000 NIS not filed under s.36(ד) (reg. 7(ה)(2)), though still prepared and approved; see step 3 |
| 2 | verbal report (דוח מילולי) | narrative account of activity for the year |
| 3 | audit committee minutes (פרוטוקול ועדת ביקורת) | the audit committee's or auditing body's recommendations on approving the financial report |
| 4 | general assembly report (דיווח אסיפה כללית) | record that the general assembly approved the financial report, with the accountant's opinion attached where one was appointed (s.38(א)(3)) |
Two disclosures travel with the online verbal report (Form 7א) whether or not the financial report is filed: Annex 1 for the s.36(ב) statement where the amuta has paid employees (reg. 7(ג)), and Annex 2 for the s.36א foreign-donation statement (reg. 7(ד)).
One attachment is missed more often than any of the four: under s.36(ב) the board must attach a statement giving a full and precise account of all payments made or undertaken to each of the five highest-paid people in the amuta, including retirement terms, and covering anything of monetary value, loans, securities and other benefits, whether paid to the person or to someone else on their behalf. Ask for it explicitly.
The annual reports are not the whole application. The certificate application set also includes a board protocol appointing an internal auditor where turnover exceeds ten million NIS, a named list of the five highest earners submitted on the Registrar's online form (a distinct form, not merely the s.36(ב) attachment), confirmation that the annual fee is paid including arrears from earlier years, and the s.36א foreign-donation statement. Unsettled arrears are a standalone reason a certificate is refused. The online system also gates the request: it cannot be completed until reports for up to four earlier years that were never filed have been filed, and filing the annual reports does not by itself request a certificate. The request is a separate submission.
Signature detail defeats applications on its own: the signatories' names must be stated beside the original signature, and the audit committee's form must expressly say whether it recommends approving the financial report. Confirm the current cycle's exact set against the Registrar's own circular, because the numbering and the online forms change between cycles.
Filing is online. If the submission is blocked, the cause is usually that the amuta's authorised role-holders are out of date rather than a problem with the documents themselves.
Filing the annual reports is mandatory in its own right. It does not depend on whether the amuta wants a certificate this year.
Change notices are a separate standing duty. Under s.38, signed by two board members and filed online within two weeks of the decision or event: a change of address or digital address, the election, appointment or end of term of a board member, audit-committee member or auditing body, the appointment of an accountant, a general-assembly resolution changing the takanon, name or objects, a resolution on authorised signatories, and notice of a lawsuit filed against the amuta or against a board member in that capacity. Stale role-holders usually mean a missed s.38 notice.
Step 5: Fix the fee tier and the deadline
The fee is annual, per calendar year, under the Associations (Fees) Regulations. The certificate request requires the fee for the year before the certificate year, so the 2026 fee for a 2027 certificate.
| Situation | 2026 amount | Timing |
|---|---|---|
| Reduced tier | 176 NIS | whole year |
| Turnover above 300,000 NIS, paid up to 31.03 | 1,338 NIS | until 31.03 |
| Turnover above 300,000 NIS, paid from 01.04 | 1,777 NIS | from 01.04 |
The reduced tier is not simply "a small amuta". Under item 2(ד) of the fee schedule it reaches an amuta in its first two years after the year of incorporation, and an amuta whose turnover, as stated in the verbal report for the last financial year whose report fell due before the fee year began, did not exceed 300,000 NIS. For the 2026 fee that is the 2024 report, due 30 June 2025. The gov.il page also names 2023 in one sentence; the regulation governs. Because the test reads a filed report, the operative lever is filing it, so have the user confirm the tier before paying. A fee paid after the end of its year is charged at the post-March rate of the year in which it is actually paid (item 2(ג)).
Two consequences worth stating up front:
- Paying early does not just save money, it is irreversible in one direction. An amuta that pays the full fee before filing its online reports is not entitled to a refund of the excess.
- Unpaid fees escalate. Debts can be transferred to the מרכז לגביית קנסות, which can levy on assets, and once transferred the fee tier can no longer be corrected.
The fee is index-linked and updated once a year, and carries no VAT component.
Step 6: Check Section 46 digital donation readiness
Only relevant if the amuta holds a Section 46 approval. If it does, this is the most urgent item in the whole review, because the approval itself is now conditional on it.
Execution instruction 11/2025 states that from 1 January 2026 amutot holding a Section 46 approval must report donations and donation cancellations through the Israeli donations system, and that "approval under section 46 is conditioned on compliance with the reporting obligation under this directive". Failing to report puts the approval at risk, not merely the donor's credit.
Check these in order, because the first two are prerequisites and an amuta that has not done them cannot report at all:
- Is the amuta registered for Tax Authority digital services, and is every person who will report registered and separately authorised?
- Has the amuta appointed a super-authorizer, who can report and authorise others on its behalf?
- Is the receipting software interfaced with the system? If not, the fallback is the online application, which requires keying every receipt by hand and is explicitly not recommended.
- Does every donation receipt carry the report number returned by the system?
Four rules that catch people out:
- Reporting runs from the first shekel. There is no minimum donation.
- The duty applies even where the amuta is exempt from issuing a receipt.
- A An anonymous donation does not entitle anyone to a tax benefit. A donation recorded with a full name but no ID number is not attributed to the donor unless the amuta later files a supplementary report adding the ID, which it can do in its portal when the donor asks.
- Cancellations are reportable too, citing the original report number.
There is no April 2026 compliance deadline. The date is 1 January 2026. If a user has been told otherwise, they have probably been given the annual-fee calendar by mistake, where 01.04 is when the fee rises from 1,338 to 1,777.
Step 7: Foreign political-entity donations
Two separate duties, with different triggers. Conflating them is the usual error.
Annual disclosure, turnover-gated. s.36א(ב)(1) requires an amuta with turnover above 300,000 NIS to state in its financial report whether it received donations from foreign political entities whose cumulative value exceeds 20,000 NIS, and if so to give the donor's identity, the amount, the purpose, and any conditions or undertakings attached, on Annex 2 of the online verbal report. s.36א(ג) requires the amuta to publish that information on its own website, and where it has told the Registrar it has no website, the Registrar publishes it on the Ministry of Justice site.
Donor naming and receipt books follow their own rules: a 100,000 NIS a year ceiling on leaving a
donor unnamed, a register of donors above 20,000 NIS, a must-name rule above 50,000 NIS where the
donor is at least 20% of turnover, and a separate donation receipt book. Read
references/donor-rules.md before answering a donor-naming question, and do not confuse the
20,000 register figure with the foreign political-entity threshold.
Quarterly reporting, NOT turnover-gated. Section 2 of the Disclosure Duty Law 2011 requires a body that received a donation from a foreign political entity to file an online report with the Registrar within one week of the end of the quarter in which the donation was received, giving the donor, the amount, the purpose and any conditions. There is no turnover gate and no amount gate on this duty.
The practical consequence: a small amuta below the 300,000 NIS turnover line that takes a single foreign political donation still owes a quarterly report within a week of quarter end, even though it owes no annual disclosure. Never answer "your turnover is under the threshold, nothing to do".
Majority foreign funding is a third duty. Under s.5א of the Disclosure Duty Law (2016 amendment), an amuta whose main source of funding, in the last financial year for which a financial report was due, was donations from foreign political entities must say so in a separate online report filed on the annual reporting date (the Registrar reads "main" as more than 50%). Until the next reporting date it must also state it prominently in its public advertising, on its home page, in its public reports, and in letters and e-mails to public servants and elected officials.
Step 8: Produce the gap report
Close with a gap report that names what currently blocks the certificate, one line per gap, each with the concrete next action and who has to take it. Order by what blocks filing first. Separate:
- gaps the amuta's own officers can close (appoint the missing organ, convene the assembly, update role-holders, appoint a מורשה-על),
- gaps that need a licensed professional (the audit itself, any amendment of the articles),
- gaps that are purely a payment or a deadline.
Say explicitly which items you could not verify and which the user must confirm with the Registrar.
Step 9: When the certificate is refused or not granted
A refusal letter is not the end of the process. Read references/refusal-path.md and work through
it in order: identify which of the four letters this is (a demand for documents, a notice of intent
to refuse, a refusal, or a demand to sign a defect-correction plan), read the response window off
the letter and diarise it, and apply the one-year bar from step 2 before planning any cure. Two
points to state every time: signing a defect-correction plan revokes a certificate the amuta
currently holds, and the acknowledgement of receipt of documents is documented for a new amuta or one without two
years of continuous activity, not as an interim
substitute for a refused one. A refusal is an administrative decision that can be answered; this
skill does not advise on challenging it, and that is the point to take a lawyer.
Step 10: Public benefit companies (chalatz)
A public benefit company is a company, not an amuta. It registers with the Registrar of Companies, is supervised by the Registrar of Endowments, gets its certificate under the Companies Law, files an additional annual return (form 5, s.141 of the Companies Law), and pays its fee at the companies unit on a separate table. Never quote the amuta fee table to a public benefit company; route it to the companies unit.
Recommended MCP Servers
| MCP | What it adds here | Install |
|---|---|---|
israel-amutot |
Registry lookup over roughly 74,880 amutot: status, financials, certificate history by year, foreign-donation records, and public benefit company records | npx -y @skills-il/israel-amutot-mcp |
budgetkey |
Whether the amuta receives state support, which raises the cost of losing the certificate | url:https://next.obudget.org/mcp |
Gotchas
- Assuming the certificate year equals the report year. It does not; it is X minus 2. This is the most expensive mistake in the domain because the user prepares a complete package for the wrong year before anyone notices.
- Quoting the fee exemption. There is no longer one. It was abolished from 2020. The gov.il fee page still displays the 2019 exemption procedure immediately above the sentence abolishing it, so an agent that stops reading early will confidently offer a dead exemption. Several published guides make exactly this error.
- Reusing 750,000 NIS as the audit threshold. It is the 1996 base and the current bookkeeping threshold. The audit amount is 1,380,630 NIS for 2026, the last earlier notice gave 1,172,933 NIS (2014), and for the 2024 and 2025 reports turnover between those two is unsettled, see step 3. Quoting the base figure tells a mid-sized amuta it needs a paid auditor when it does not.
- Treating an expired extension as available. The Lion's Roar extension moved 2025 reports to 31 July 2026 and covered only the 2027 certificate; both that date and the 30 June 2026 window for the 2026 certificate are in the past. Check the Registrar's news page for a current extension rather than repeating an old one or asserting that none exists.
- Telling a small amuta it need not prepare accounts. s.36(א) binds every amuta. Only the audit is banded. At or below 500,000 NIS it need not FILE the financial report, which is different.
- Answering "under the threshold, nothing to do" on a foreign political donation. The quarterly report under the Disclosure Duty Law has no turnover gate and is due within a week of quarter end. Only the annual disclosure is turnover-gated.
- Checking that the organs exist without checking who sits on them. A family majority, a salaried employee on the board, or one person on both the board and the audit committee is a defect. Existence is not compliance.
- Treating a refusal as final. It is an administrative decision with a response window. Do not promise an interim status; ask the Registrar whether any applies. Never close on "the certificate was refused".
Bundled Resources
references/domain-checklist.md: the coverage contract, with every band and duty the skill must cover and what is explicitly out of scope.references/filing-package.md: the four documents, the s.36(ב) attachment, and the certificate application set.references/donor-rules.md: when a donor may stay unnamed, the donor register, and the donation receipt book.references/refusal-path.md: the four refusal letters, the defect-correction plan, the lesser confirmation, and challenging a refusal.scripts/band_check.py: given turnover, certificate year and Section 46 status, prints the bands, the fee tier, the report year and the deadline. Pure computation, no network access required.
Reference Links
| Source | URL | What to Check |
|---|---|---|
| Registrar, proper management certificate | https://www.gov.il/he/service/association_certification_of_proper_management | current application route and forms |
| Registrar, annual fee | https://www.gov.il/he/service/association-annual-fee | the operative fee tiers for the year |
| Registrar, reporting duties | https://www.gov.il/he/service/association_annual_reporting_obligations | duties for amuta and chalatz, forms |
| Registrar news | https://www.gov.il/he/pages/news-rejection | whether an extension is currently in force |
| Associations Law | https://he.wikisource.org/wiki/חוק_העמותות | ss.19, 26א, 30א, 32, 33, 34ג, 36, 36א, 37, 38 and the Second Schedule |
| Associations (Forms) Regulations | https://he.wikisource.org/wiki/תקנות_העמותות_(טפסים) | reg. 7(ה) filing exemption, reg. 7א donor figures |
| Execution instruction 11/2025 | https://www.gov.il/BlobFolder/policy/inst-11-2025/he/IncomeTax_inst-11-2025.pdf | Section 46 donation reporting rules |
Troubleshooting
| Symptom | Likely cause | What to do |
|---|---|---|
| Online filing rejects the submission | the amuta's registered role-holders are stale, so the filer is not authorised. This is the most common cause, though other causes exist and the portal error text is rarely specific | update role-holders with the Registrar, then retry |
| Certificate refused despite documents filed | reports filed for the wrong year, or an organ the turnover band requires was never appointed | re-run steps 2 and 3 |
| Donation report returns no report number | the report was not accepted | retransmit until a valid number is returned; instruction 11/2025 requires this rather than treating a silent failure as success |
| Amuta paid 1,777 and believes it qualified for 176 | full fee paid before the online reports were filed | no refund is available; file the reports so the following year is correct |
| Turnover sits near a threshold | the deciding figure is the reported year's turnover, and which audit amount applies to it is not settled | apply the step 3 zone rule; between the last two gazetted amounts, recommend the conservative course and have the amuta confirm |