אוסמוז

אוסמוז

Meeting preparation · Confidential

The lawyer
Regulation, import, contracts, shareholders’ agreement

First of the three meetings · 77 questions, 31 of them critical

Every question carries its legal reference. The critical questions decide whether the project is feasible at all.

The project in eight lines. We are setting up a cleaning company in Israel specialised in pressure washing, with a drone as its second tool for building façades. Two brothers as partners: Jonathan, an engineer and former certified RGE auditor, ten years in Israel; David, twelve years of pressure washing in France. The same van and the same equipment serve two trades: façade washing carried by a drone fed from the ground, and ground-level pressure washing — car parks, lobbies, terraces, drainage. Pressure washing invoices from month three and depends on no aviation authorisation. The drone waits for a special operating authorisation. Founders’ equity contribution: 600 000 ₪. First drone job targeted in month seven.
What we need from you, precisely. Four things, in this order: tell us whether the trade can be carried out and on what conditions — that is block B, and nothing is decided before it; secure the import of the flying equipment, including the spectrum approval and the customs classification, because an aircraft held at the port stops the whole timeline; draft our contracts — clients, employees, and the postponement clause that protects a business dependent on the weather and on an authorisation; and write the shareholders’ agreement between two brothers, while everything is still going well. This document does not replace your opinion: it exists so the meeting starts from precise texts.
How to read this document. Every question carries its legal reference, so we work on text rather than on impressions. Questions marked CRITICAL determine whether the project is feasible: if only six can be asked, ask those. A line for the answer follows each question, and the page prints as it stands. Tax, company structure and financing are the subject of two other meetings: the accountant and the bank.
The tipping point of the project, in one sentence. The 2024 regulation requires a minimum distance between the drone and any uninvolved person equal to the greater of the flight height or 50 metres (תקנה 32(א)(2)). Cleaning an occupied façade is therefore impossible under the standard regime. The whole project rests on obtaining a הרשאה להפעלה מיוחדת (special operating authorisation, תקנות 37-43) waiving that article. The questions in block B are the most important in this document.

AApplicable regime and weight of the aircraft

The loaded weight decides the entire legal regime, and with it the budget, the timeline and the feasibility.

A1

Do you confirm that תקנות הטיס (הפעלת מערכת כטב״ם קטן), התשפ״ד-2024 (the Aviation Regulations on the operation of small unmanned aircraft systems) is the text in force today, and that it has not been amended since publication?
קובץ תקנות 3192 · in force 11.08.2024
Answer:
A2

Is the 25 kg threshold understood as maximum take-off mass, accessories included? The aircraft carries no water — it is fed by a hose from the ground — but it carries the nozzle bar and lifts the weight of the loaded hose. Does that lifted weight count towards take-off mass?
תקנה 1, definition of כטב״ם קטן (small unmanned aircraft)
Answer:
A3

If the threshold is crossed: what exactly changes under the 1981 regime for an aircraft above 25 kg? Certificate of airworthiness, air operator status, real lead times, order of magnitude of the cost?
תקנות הטיס (הפעלת כלי טיס וכללי טיסה), התשמ״ב-1981
Answer:
A4

תקנה 180ז of the 1981 regulation, which some sources quote for “250 m from people and 50 m of height”, has it been repealed for aircraft under 25 kg? Does it remain applicable above that?
Answer:
A5

Does a modified aircraft — washing kit, pump, supply hose from the ground — lose the benefit of its original registration? Is a technical validation of the modification required?
Answer:

BThe flight waiver — the heart of the file

Without this authorisation there is no business. With it, there is a barrier to entry that a competitor cannot buy.

B1

Do you confirm our reading: תקנה 32(א)(2) effectively prohibits façade cleaning in a built-up area, since it imposes a minimum distance of at least 50 metres from any uninvolved person?
תקנה 32(א)(2) · 2024 regulation
Answer:
B2

Does the הרשאה להפעלה מיוחדת allow a waiver of תקנה 32 for this specific use? Do you know of a precedent granted to a cleaning or façade inspection company in Israel?
תקנות 37-43, פרק ד׳ · 2024 regulation
Answer:
B3

Can a single authorisation cover the whole activity — all our sites, across the country, over several years — or is one application needed per site, per city, or per building?
The most structuring question for the business model: it decides whether we can run 15 to 30 sites a month.
Answer:
B4

What does the risk management plan required in support of the application actually contain? Is there an expected format, or a template already accepted by the רת״א (Civil Aviation Authority)?
תקנה 38 · documents required for the application
Answer:
B5

Real processing time, end to end? Total expected cost: official fees, regulatory consultant fees, your own work?
Answer:
B6

What conditions does the רת״א usually attach to this type of authorisation: ground observers, safety perimeter, wind limits, capped height, enhanced qualification of the remote pilot?
תקנות 39-40 · conditions and proof of competence
Answer:
B7

The ICD organisation holds a collective authorisation valid from November 2024 to November 2028, waiving תקנות 26, 27, 32 and 35. Does it cover flight close to an occupied façade, or only night flight and flight beyond visual line of sight? Would joining it save us time?
Answer:
B8

Can the application be filed before the drones have been bought and registered? This is a cash question: we would rather not tie up 135 000 ₪ — the delivered cost of a first aircraft — before we are sure of the authorisation.
Answer:
B9

The 100-metre height ceiling blocks towers above 30 floors. Is the waiver of תקנה 35 obtained in the same application as the waiver of תקנה 32, or separately?
תקנה 35(א)(2) · max height 100 m, 60 m in designated areas
Answer:

A+Import, customs and registration of the equipment

Questions added after sourcing the flying equipment. The 25 kg threshold returns here from another angle: the manufacturer’s.

A6

Is the 25 kg threshold assessed on the maximum take-off mass declared by the manufacturer, or on the mass actually configured at take-off? Does an aircraft with a manufacturer MTOW of 33 kg, which we would operate only at 20 kg, fall under the lighter 2024 regime or under the 1981 one?
Decisive question for the choice of equipment — the answer rules out or brings back several models.
Answer:
A7

Is the spectrum approval from the Ministry of Communications (אישור תקשורת 1301) genuinely mandatory before the goods arrive? What is the real lead time, and does an aircraft already CE certified in Europe benefit from a simplified procedure, or must it be tested again in a laboratory?
תוספת 2 לצו יבוא חופשי · authority: 03-519-8154 — this is the only blocking filter identified at import.
Answer:
A8

Is there an official list of drone models approved by the רת״א? If not, what is the exact procedure to register an aircraft of which no unit has ever been registered in Israel? Should we expect extra delay because there is no precedent?
We found no public list — registration appears to be done aircraft by aircraft.
Answer:
A9

Must the customs classification we intend to use (8806.23 for an aircraft of 7 to 25 kg, against 8806.24 above that) be supported by a manufacturer’s certificate attached to the declaration, to avoid reclassification by customs?
Customs duty is nil in both cases, but the classification exposes the weight question to the administration.
Answer:
A10

The customs duty exemption on this code is shown as valid until 31 May 2028. Is it fixed at the order date or at the clearance date?
Answer:
A11

Who must be the importer of record: the company, a licensed customs broker, or the supplier on DDP terms? What do you recommend for a first import, and which documents must we give the broker — invoice, packing list, certificate of origin, technical data sheet, radio declaration of conformity?
Two separate imports in month 2: one aircraft from France, one from China through an Israeli distributor. Estimated broker budget 1 500 to 4 000 ₪, to be quoted.
Answer:
A12

We want to entrust you with the customs file from end to end — filing, exchanges with the administration, clearing any hold. Is that a mandate you take on, alone or with a broker, and at what cost? If not, which professional should we appoint, and under what form of power of attorney?
An aircraft held at the port ties up 135 000 ₪ and pushes back the whole regulatory timeline.
Answer:
A13

If customs reclassifies the goods (8806.23 to 8806.24) or challenges the declared value: what is the appeal procedure, within what deadline, and must we post a guarantee or deposit the duty to release the goods in the meantime?
Customs duty is nil under both headings, but a classification dispute exposes the weight question to the administration — and it is the weight that decides the aviation regime.
Answer:
A14

Is there a temporary admission regime or an ATA carnet allowing a demonstration aircraft lent by the manufacturer to enter the country without paying import VAT, for a few weeks of testing before purchase?
That would let us test before committing 270 000 ₪.
Answer:
A15

Do spare parts, lithium batteries and consumables imported later during operations follow the same regime? Are batteries subject to a specific transport or import regulation?
Answer:
A16

Are the manufacturer’s warranty and after-sales service of an aircraft imported directly from France enforceable in Israel? What should the purchase contract provide so that we are not left without recourse in case of a defect — governing law clause, competent jurisdiction, obligation to supply parts?
The Hercules 10 has no distributor in Israel: we would be our own importer and our own after-sales service.
Answer:

CFlight coordination and response times

The irreducible delay between signing a quote and carrying out the job determines what we can promise clients.

C1

For a flight that is otherwise compliant, is prior coordination mandatory everywhere, or only in restricted airspace? What share of the Israeli urban fabric is concerned?
תקנות 33-34 · restricted and dangerous areas
Answer:
C2

Is the seven working days often quoted for מודיעין טיס (aeronautical information service) a regulatory deadline or only a practical one? On what text does it rest?
Answer:
C3

Is there a simplified procedure or a framework authorisation with מודיעין טיס for an operator filing repeated, similar requests?
Answer:
C4

Who must file the request: the remote pilot, the company, or an appointed service provider? Can we delegate it to our back office?
Answer:
C5

Is the Vega UTM system mandatory today for a commercial operator, or still in a restricted pilot phase? From what weight?
Answer:
C6

In the event of a sudden security restriction decided by the air force, how much notice do we get in practice, and where can it be checked reliably?
Answer:

DInsurance

The legal minimum amount drives our budget and the granting of operator status itself.

D1

Do תקנות הטיס (חובת ביטוח בהפעלה מסחרית של כלי טיס), תשע״ח-2017 apply to כטב״ם? What is the minimum cover required?
Text not accessible in our research — a budget line the bank will require.
Answer:
D2

Is a specific insurance certificate required in support of the application for the special operating authorisation?
Answer:
D3

Which damages are covered and which are usually excluded: broken glazing, water ingress into a flat, damage to a coating, the aircraft falling on a passer-by or a vehicle, damage to a neighbour’s property?
Answer:
D4

Does Israeli law provide any ten-year warranty or long-term liability applicable to this type of maintenance service?
Answer:
D5

We also carry out ground-level pressure washing. Do we need two separate policies or one covering both activities?
Answer:

EPenalties and personal liability

We want to know the exact risk before exposing our personal assets.

E1

What is the actual scale of penalties for a flight carried out in breach of the distance rule: administrative fine, criminal prosecution, amounts?
חוק הטיס, התשע״א-2011 · penalty regime
Answer:
E2

Does liability rest with the company, the remote pilot, or the director personally?
Answer:
E3

Does a breach automatically lead to suspension or revocation of the operating authorisation? What appeal, and within what deadline?
תקנה 43 · suspension of up to one year, appeal within 30 days
Answer:
E4

If our remote pilot commits a fault: does the company lose its authorisation, or only the pilot his licence?
Answer:

FPrivacy, building committee and neighbours

This is the most likely source of day-to-day litigation, and it does not fall under aviation law.

F1

Under the חוק הגנת הפרטיות, התשמ״א-1981 (Privacy Protection Law): from what point does flying along a façade with an on-board camera amount to an infringement of an occupant’s privacy?
Answer:
F2

Is a written agreement from the ועד בית (building committee) enough to cover us against an opposing flat owner? Do we need a majority of the residents’ meeting, a qualified majority, or unanimity?
Answer:
F3

Can you draft for us a template information notice to residents and a prior consent form, to be signed by the property management company before each job?
Answer:
F4

Does disabling or masking the camera reduce the legal risk, or does the flight alone still create it? And is the camera in any case mandatory to fly in compliance?
Answer:
F5

Can a neighbour in an adjoining building, who is not our client, obtain an injunction stopping the job?
Answer:

GEmployment and work contracts

Two points carry immediate criminal consequences: the minimum wage and the pilot’s status.

G1

The minimum wage is 6 443.85 ₪ gross since 1.4.2026. Is a sales role paid 3 000 ₪ fixed plus commission lawful if the total exceeds the minimum in some months? Must we guarantee a floor at the legal minimum?
חוק שכר מינימום (Minimum Wage Law) · a breach is a criminal offence, not a simple tax adjustment.
Answer:
G2

Can the remote pilot be self-employed (עוסק מורשה, registered dealer), or is the risk of reclassification as an employee too high?
Answer:
G3

We are hiring a pilot who is already licensed rather than training one. What clauses can we hold against his departure: fixed-term commitment, conditional seniority bonus, non-competition, non-solicitation? And if we later fund an additional qualification, is a clause for repayment on a declining scale valid?
The real issue: our operating authorisation rests on the competence of one person who can leave from one day to the next.
Answer:
G5

Ground cleaning starts in month three, before any aviation matter. Do we need a רישיון עסק — a municipal business licence — for a pressure washing company working on third-party premises, and for storing equipment and products in a unit? If so: which municipality is competent, what lead time, what cost, and does the drone add a category?
This is the only municipal permit that could really concern us, and it governs the start of pressure washing — therefore the whole cash plan for months 3 to 7.
Answer:
G4

What occupational safety obligations fall on us for drone-assisted work at height and for ground-level pressure washing? Must we appoint a designated safety officer?
Answer:

HClient contracts

Our lead times depend on authorisations we do not control, and our cash depends on a deposit. The contract must carry both.

H1

How should we draft an enforceable postponement clause covering bad weather, refusal or delay of a flight authorisation, and a sudden security restriction? Can it exclude any compensation to the client?
Answer:
H2

Is a 40% deposit on order enforceable against a building committee? Our financial forecast depends on it directly.
Without that deposit, the 60-day collection lag opens a hole the loan does not fill.
Answer:
H3

Is a limitation of liability clause valid under Israeli law for this type of service, and up to what cap?
Answer:
H4

What should we watch in an annual framework contract with a property management company: term, exclusivity, termination, price review?
Answer:
H5

Who contracts with us: the ועד בית, the property management company, or each flat owner? Who is legally our debtor if an invoice goes unpaid?
Answer:

JVehicle, towing and type approval

These questions fall under road traffic law, not aviation law. The tax side of the vehicle is handled with the accountant.

J1

What trailer weight is allowed today with a category B licence? Our sources contradict each other: תקנה 180(ב) gives 1 500 kg gross vehicle weight for the trailer taken alone; a trade body documents an amendment of 11 October 2023 imposing a combined vehicle plus trailer ceiling of 5 000 kg; a third source states 4 250 kg combined. Which version is in force?
תקנה 180(ב) לתקנות התעבורה, התשכ״א-1961. With a van of 3 990 kg gross vehicle weight, the three readings give 1 500 kg, 1 010 kg and 260 kg of permitted trailer respectively.
Answer:
J2

Exact procedure to fit a towbar: are the written authorisation of the משרד הרישוי (licensing authority) and the entry on the registration document mandatory in every case? What lead time, what cost, and who applies — the dealer or us? And the trailer itself: registration, its own plate, annual test, in what order?
Procedure police.gov.il 08.04.04.15 — failing that: fine and immobilisation of the vehicle.
Answer:
J3

We are fitting in the van a 400-litre tank, a generator, a high-pressure pump and a reverse-osmosis unit, about 930 kg. Does this conversion change the type approval of the vehicle? Do we need validation by the importer, an inspection at the מכון התקנים (Standards Institute), or a new axle-by-axle weighing? From what fleet size must we appoint a קצין בטיחות (safety officer)?
A point often discovered after the order, although it governs the choice of the fit-out firm.
Answer:
J4

Does a category B licence obtained before 2007 allow driving up to 4 000 kg gross vehicle weight? If not, is the C1 licence required from 3 501 kg? Please confirm the prerequisite of a category B licence held for one year and the absence of any other condition for a company director.
The vehicle selected has a gross vehicle weight of 3 990 kg — the answer decides whether we must budget a C1 for each driver, that is 6 500 to 10 000 ₪ and two to three months per person.
Answer:
J5

Does carrying pressurised water and a petrol generator in a commercial vehicle require particular safety equipment, marking, or a declaration? And the drone itself: does its road transport, lithium batteries included, fall under dangerous goods regulations?
Answer:

KThe shareholders’ agreement

Two brothers, equal shares, no salary in the first year. This is exactly the configuration where nothing gets written down — and exactly the one where it must be.

K1

What must a shareholders’ agreement contain under Israeli law to be fully enforceable, and what belongs in the articles of association rather than in the agreement? Are there clauses standard in France that carry no weight here?
We are starting 50-50 between two brothers. We know that is the split that deadlocks fastest in case of disagreement.
Answer:
K2

How should we organise breaking a deadlock: casting vote, third-party arbitrator, appointed expert, cross-purchase clause? What do you recommend in concrete terms for two equal partners who are also brothers?
Answer:
K3

The 600 000 ₪ contribution will not necessarily be paid in strictly equal parts, and neither will the work put in. How should the agreement handle an unequal contribution — as share capital, as a shareholder loan, or through a catch-up clause?
The form of the contribution is decided with the accountant; protecting whoever puts in more is decided here.
Answer:
K4

What exit clauses should we provide: approval of transferees, pre-emption, tag-along, buy-back clause on departure, disability or death? What valuation method should we use for a services company less than three years old, and must it be written now?
Answer:
K5

Is an exclusivity and non-competition clause between partners enforceable in Israel, and for how long after departure? We also run a pressure washing activity: must the boundary between the two be written down?
Answer:
K6

The founders take no salary in the first year and are paid out of profit. How can that commitment be secured in the agreement — distribution cap, mandatory reserve, minimum cash condition before any dividend?
Answer:
K7

Who binds the company day to day, and above what amount is the signature of both partners required? We want a simple rule, written before the first bank commitment.
The 369 000 ₪ balloon loan and any personal guarantee are the first commitments concerned.
Answer:
K8

Does what we build ourselves — website, CRM, authorisation file templates, operating procedures, video library of our jobs — belong to the company or to its author? Is an express assignment of rights needed, and in what form?
The authorisation file and the procedures are our barrier to entry. They must belong to the company, not to one of us.
Answer:
K9

Should we already provide for the entry of an investor or a third operating partner, or is that so premature that it becomes counterproductive?
Answer:

LThe name and the trade mark

The company will be called אוסמוז · OSMOZ. The name describes a process — osmosis-treated water that dries without marks — and that is precisely what may cause trouble at filing. Nothing goes into production, neither vehicle wrap nor embroidery, before your answer.

L1

OSMOZ describes a process. Can an Israeli examiner find it descriptive and refuse the filing? Are the spelling with a Z rather than SE, and the compulsory pairing with the Hebrew word אוסמוז, enough to make the whole distinctive?
חוק סימני מסחר (Trade Marks Ordinance) · osmosis is אוסמוזה; we are filing אוסמוז, the word cut short of its final ה, which does not exist in the dictionary.
Answer:
L2

Prior-rights search at the Israeli trade marks register (רשות סימני המסחר, Trade Marks Office): do you handle it, within what time and at what cost? Should it be extended to European and international marks designating Israel, and to company names already registered at the רשם החברות (Registrar of Companies)?
Answer:
L3

Which Nice classes should we target: building cleaning, drone services, technical inspection, thermography? Is it better to file broadly straight away, or narrowly and extend when the new services arrive?
Extensions planned in the dossier: solar panels, thermographic inspection, anti-moss and water-repellent treatment.
Answer:
L4

Should we file three separate signs — the Hebrew word אוסמוז, the Latin word OSMOZ, and the composite logo with the emblem — or is a single filing enough to protect the whole? What is the extra cost of each additional filing?
Answer:
L5

Does the emblem — a stylised rotor inside a graduated ring — fall under trade mark law, copyright, or both? Must the designer who redraws it assign his rights to us in writing, and in what form?
The current drawing is a concept sketch; a designer must redraw it in vector form before any production.
Answer:
L6

Can we use the name before registration — website, wrapped vehicles, quotes, invoices — or must we wait for publication? What risk do we take if an opposition is filed once two vehicles are already wrapped and the workwear embroidered?
Wrapping the two vehicles costs about 25 000 ₪ and takes place in month four of the plan.
Answer:
L7

What is the opposition procedure and deadline after publication? And if a third party uses a similar name without having filed it, what remedies do we have once our mark is registered?
Answer:
L8

Must the company name on the register be identical to the trade mark? Can the trading name differ from the corporate name, and must a separate שם עסק (business name) be registered?
Answer:
L9

Domain name osmoz.co.il and business listing: does reservation alone create a right of use, or does only the trade mark filing count? What can we do if the domain is already held by an inactive third party?
Answer:

§What to leave this meeting with

An oral answer cannot go into a bank file. Leave with something written.

  • A written note on questions B1 to B4 — that is the document securing everything else, the bank file included.
  • Written confirmation of the 25 kg threshold including the load, so we can freeze the choice of equipment.
  • A written estimate of the total time to the special operating authorisation, and of its full cost.
  • The name of a regulatory consultant approved by the רת״א, with an indication of price.
  • The name of an aviation insurance broker already covering drone operators.
  • The written procedure for the 1301 spectrum approval and the customs classification of the aircraft.
  • The result of the prior-rights search on OSMOZ, the recommended filing classes, and the go-ahead — or not — for vehicle wrap and embroidery.
  • Your quote: incorporation, shareholders’ agreement, client and employment contracts, authorisation file.
  • Your lead times, item by item — that is what will feed our timeline.
The order of the three meetings. The lawyer first: find out whether the trade can be carried out, and on what conditions. The accountant next: settle the structure, the tax treatment and the split between equity and borrowing. The bank last, with a request already decided and two written opinions in hand. Nothing is ordered before the answer to block B.
Reservation. These references come from desk research carried out on 25 August 2026, based on the official text published in the regulations gazette. The consolidated Nevo text and the 2011 Aviation Law could not be consulted directly. This document is meant to question the lawyer; it does not replace his opinion.