The Foreign Influence Registration Scheme (FIRS) came into effect on 1 July 2025. FIRS requires certain types of activities which are directed by a foreign power to be registered on a UK government portal. Failure to do so is a criminal offence.
When carrying out activities (e.g. research) in partnership with an overseas government, it is important to consider whether the activity falls within the scope of FIRS. FIRS applies to activities carried out by the University of Greenwich and also to activities carried out by individuals when they are acting on their own behalf.
What is FIRS?
The Foreign Influence Registration Scheme (FIRS) under the National Security Act 2023 is a two-tier scheme which is intended to provide transparency over foreign influence in UK politics and provide greater assurance around the activities of the foreign powers that pose the greatest risk to the UK. The scheme came into effect on 1 July 2025.
FIRS does not prevent activities from taking place, but requires activities which fall within the scope of the scheme to be registered via a government portal within 28 days of a direction to carry out the activity being provided by a foreign power (10 days if the activity falls within the scheme’s ‘enhanced tier’). Information submitted via the portal will be used to maintain a public register of political influence activities. Failure to register is a criminal offence.
The scheme applies to activities carried out by organisations, unincorporated associations and individuals. There is a three month grace period from 1 July 2025 to register existing arrangements, with the FIRS deadlines applying to new arrangements entered into after 1 July 2025.
What are the two FIRS tiers and what do they cover?
FIRS has two tiers:
- An enhanced tier which requires individuals or organisations to register if they are directed by a specified foreign power to carry out ‘relevant activities’ in the UK. ‘Relevant activities’ by default means all activities, including but not limited to commercial activities, the provision of goods and services, research activities and attendance at events. Currently, only activities at the behest of the governments of Russia or Iran or entities controlled by them have been designated by the government as falling within this tier.
- More relevant to UK universities is the political influence tier which requires individuals or organisations to register where they are directed by a foreign power (except the Republic of Ireland) to carry out, or arrange for someone else to carry out, ‘political influence activities’ in the UK.
For the purposes of the political influence tier:
- A foreign power includes a foreign government or part of a foreign government (e.g. a ministry, agency or authority), a local government authority in a foreign country or the governing party of a foreign government. State owned companies are not considered foreign powers so are not covered by the scheme, nor are arrangements with inter-governmental organisations (e.g. the EU, ASEAN).
- The directions of a foreign power can be formal or informal instructions to act and can include coercion.
- Political influence activities covers communications (including meetings) with senior public officials or politicians, publications, and the provision of money, goods or services to an individual or entity in the UK, which is intended to influence: an election or referendum in the UK; a decision of a minister or government department (including in the devolved administrations); the proceedings of a UK political party; or a member of the House of Commons, the House of Lords or an assembly in Scotland, Wales or Northern Ireland.
FIRS applies to activities in the UK, not those carried out wholly overseas. The government’s guidance for the academic and research sector states that FIRS does not require any due diligence to be performed on overseas entities. The obligation on the UK organisation or individual to register under the political influence tier applies if they know, or reasonably ought to know, that they are carrying out ‘political influence activities’ at the direction of a foreign power.
There are exemptions where FIRS does not apply: e.g. diplomats, lawyers carrying out legal activities, news publishers, arrangements where a UK crown body is a party, and publications where it is reasonably clear that the activity was carried out at the direction of a foreign power. Research projects do not require registration under the political influence tier if the UK university will have complete discretion over how the results are presented.
What types of activities might require registration?
The government has published guidance for academia and the research sector to help HE sector organisations understand what types of activities may require registration under FIRS.
Examples of the types of activities that may require registration under FIRS include (but are not limited to):
- Workshops, conferences etc which are intended to influence politicians or senior public officials attending the event, where the workshop, conference etc is at the direction of a foreign power seeking to influence UK government policy.
- Research projects which are funded or directed by an overseas government which is seeking to influence UK government policy. However, a research project would not need to be registered if it was clear from the published results that it was carried out at the direction of a foreign power; or if the UK university will have complete discretion over how the results of the project are presented.
- Lobbying of the UK government or UK politicians which a UK university or an individual is required to carry out under an arrangement with a foreign power.
- Any type of arrangement with the governments of Russia or Iran or government-controlled entities in those countries is likely to require registration under the ‘enhanced’ tier.
Further guidance about what is covered is provided in the government’s guidance for academia and the research sector.
Who is required to register?
If an activity that falls within the scope of FIRS is carried out by the University (including by staff acting on the University’s behalf), the University must register the activity on the government’s portal.
FIRS also applies to activities carried out by individuals and groups, who may be required to register activities which they carry out on their own behalf. For example, a staff member undertaking private consultancy may have to register if the activity falls within the ‘political influence tier’. Similarly, a student society which carries out political influence activities (e.g. lobbying UK politicians) at the direction of a foreign power would be required to register the activity.
What if we don’t register?
Failure to register when required is a criminal offence, which can be punished by imprisonment and a fine.
Who should I contact if I think my activity is covered by FIRS?
Most University of Greenwich activities won’t fall within the scope of FIRS. However, it’s important to identify any activities which may be covered by FIRS at an early stage, so that they can be registered within the scheme’s deadlines (28 days for the ‘political influence’ tier and 10 days for the ‘enhanced’ tier).
If you think your activity may require registration under FIRS: