Last updated: 15 May 2025
The UK's Foreign Influence Registration Scheme (FIRS) will come into force on 1 July 2025. Introduced under the National Security Act 2023, the scheme is intended to strengthen the resilience of the UK political system against covert foreign influence and to provide greater assurance around the activities of certain foreign powers or entities that are a national security risk.
Overview
FIRS is a two-tier scheme:
- the "political influence tier" requires individuals or entities to register where they are directed by a foreign power to carry out, or arrange for others to carry out, political influence activities in the UK;
- the "enhanced tier" requires registration of a broader range of activity where a person is acting at the direction of specified foreign powers or entities that have been assessed as posing a potential risk to UK safety or interests. It also requires specified entities to register activities which they carry out themselves in the UK.
The political influence tier
In brief, the political influence tier requires registration of a "foreign influence arrangement" within 28 days of the arrangement being made. A "foreign influence arrangement" is any arrangement, whether formal or informal, that involves direction from a foreign power to carry out political influence activities in the UK.
Activities will be "political influence activities" if they meet both of two criteria. The first is that they involve one of these activities: a communication to a senior public official or politician; a public communication, except where it is reasonably clear that it is made at the direction of a foreign power; or the provision of money goods or services to an individual or entity in the UK. The second criterion is that the purpose, or one of the purposes, of the activity is to influence one of the following: a UK election or referendum; a decision of a Minister or Government department; the proceedings of a UK registered political party; or a Member of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament or Senedd Cymru.
The Government's guidance on the political influence tier gives several examples of arrangements that would, or would not, require registration, illustrating that the political influence tier will capture arrangements beyond traditional lobbying. Examples of registerable arrangements include:
- A charity in an arrangement with a foreign power to arrange for a wildlife expert to influence a UK political party's manifesto commitments.
- An entrepreneur in an arrangement with a foreign power to make investments to influence legislation affecting trade with a particular country.
- A language and cultural institute in an arrangement with a foreign power to promote the teaching of the language of a particular country in UK secondary schools.
The enhanced tier
The enhanced tier requires registration of formal or informal arrangements made with a specified foreign power or foreign power-controlled entity where an individual or entity is directed by the specified foreign power or foreign power-controlled entity to arrange for, or carry out, "relevant activities" in the UK. The foreign powers currently specified under the enhanced tier are Russia and Iran.
Registration of “foreign activity arrangements” must be completed within 10 days, beginning with the day on which the arrangement is made, and prior to any activities pursuant to the arrangement being carried out.
"Relevant activities" by default include all activities in the UK. This includes, but is not limited to, commercial activities, research activities and the provision of goods and services. The scope of "relevant activities" may be amended by the Secretary of State, so that in due course arrangements with different specified foreign powers or entities may require registration of different types of activities.
Public register
Certain information related to those registered under both the political influence and enhanced tiers will be included on a public register, unless an exception to publication applies. Exceptions to publication apply in the following circumstances:
- Where there is a risk that publication would prejudice the safety or interests of the UK.
- Where there is a risk that publication would prejudice the prevention or detection of crime, a criminal investigation or criminal proceedings.
- Where there is a significant risk that publication would put any individual's safety seriously at risk.
- Where publication would involve the disclosure of commercially sensitive information.
Sector specific guidance
The Home Office has published an extensive collection of guidance on FIRS, including sector specific guidance for sectors including academia and research, charities and civil society, defence and security, business and media.
Interaction with National Security and Investment Act
FIRS will be a separate regime to the UK's existing National Security and Investment Act regime. While the NSI Act regime requires Government approval before investments in certain sectors of the economy can be completed (see our separate NSI Act briefing), the Government's policy paper on FIRS notes that FIRS does not require that activities or arrangements be approved before they can take place. The guidance on FIRS also stresses that the requirements of FIRS, the NSI Act and the Academic Technology Approval Scheme (ATAS) are separate and distinct and that registration, or approval, under one of these schemes is not equivalent to compliance with them all: "In circumstances where registration or approval is required under multiple schemes, these will need to be processed separately."
Exemptions and penalties
There are a number of exemptions from registration, including for example any arrangement with the Republic of Ireland. Foreign powers, diplomatic family members, lawyers carrying out legal activities, news publishers and sovereign wealth funds and public pension funds carrying out investment-related activities are exempt from registration under the political influence tier. Among those exempt from registration under the enhanced tier are foreign powers, diplomatic family members, those providing essential services to a diplomatic mission or consulate and lawyers carrying out legal activities.
The Home Office will be responsible for the administration of FIRS, with the power to issue information notices to registrants or individuals or entities who are believed to be party to, or acting pursuant to, a registrable arrangement. The scheme contains a number of offences, including for those who fail to comply with registration requirements, or fail to respond to information notices. Where registration requirements have not been met, there are also offences for those who carry out activities pursuant to a relevant arrangement.
Next steps
The requirements of FIRS come into force on 1 July 2025. Where a registerable arrangement is already in place on 1 July 2025, there is a three-month grace period to register this arrangement. This grace period applies to arrangements both under the political influence tier and the enhanced tier.