Foreign Influence Registration Scheme (FIRS)

The UK Government has introduced The Foreign Influence Registration Scheme (FIRS) to protect the safety and interests of the UK by improving the understanding of activity taking place in the UK at the instruction of a foreign state or certain foreign state‑controlled organisations. The legislation requires individuals or organisations who are carrying out certain activities at the direction of a foreign power to register with the scheme.

FIRS came into force on 1 July 2025. Organisations and individuals have a legal obligation to comply with (FIRS).  In-scope activities must be registered within the scheme standard timeframes (28 days for the Political tier and 10 days for the Enhanced tier). There is a three-month grace period (to 1st October 2025) for registration of pre-existing live, in-scope activities.

FIRS is detailed in the National Security Act 2023 (Part 4). Failure to comply with the requirements of the scheme may constitute a criminal offence with a maximum penalty of 5 years imprisonment.

The Government has published detailed guidance specifically for universities and researchers. 

How the FIRS Registration Scheme works

The scheme requires individuals and organisations to register their arrangements with foreign powers and certain foreign power-controlled entities where they are directed to carry out certain activities in the UK.

The scheme is split into two tiers:

• The Political Influence tier, which requires the registration of arrangements with any foreign power (except the Republic of Ireland) to carry out political influence activities in the UK
• The Enhanced tier, which requires the registration of arrangements to conduct a wider set of activities but only with the foreign powers or foreign power-controlled entities which have been specified in regulations. Currently, this applies to Iran and Russia, and certain entities in those countries.

Registration requirements only apply where there is a “direction” from a foreign power to act. A “direction” from a foreign power may be formal (such as a contract or payment) or informal (such a reciprocal or in-kind arrangement or coercion). The legislation does not prohibit activity and it is not an approval process, but the activity must be registered within the specified timeframes to promote transparency about the nature of foreign influence in the UK.

Registration is made online. 

Responsibility for registration

Any organisation (e.g. the University of Essex) or an individual (a member of staff or a student) who enters an arrangement where there is a “direction” from a foreign power to act is required to register.

If the University identifies a registerable arrangement, then registration will be made on behalf of the University by the REO Due Diligence Team.  We will check for potential FIRS registration requirements as part of our Due Diligence checks on funded projects.  Please notify reo-due-diligence@essex.ac.uk if you are aware of an arrangement that is registerable by the University. Individuals who have been directed by a foreign power to carry out political influencing activities in their capacity as a member of the University should notify the REO Due Diligence Team.

Where an individual member of staff or student has entered into a registerable arrangement in their own name, the individual is responsible for registration.

How to decide if FIRS applies to you

FIRS registration will apply if you have made an arrangement (either formal or informal) with a foreign power (except the Republic of Ireland) to carry out political influencing activities in the UK.

The vast majority of collaboration or research arrangements do not need to be registered, and registration would only be required under the Political tier if the research formed part of an intentional effort by a foreign power to influence the UK’s democracy.

Under the Enhanced tier, consideration will be given to funding where it has conditions attached for it to be used in a particular way. However, the states covered by the Enhanced tier are currently restricted to only Russia and Iran. 

Research collaboration with international colleagues, even if the work has a political dimension, is not covered by FIRS. Activity is only registerable where it is carried out in the UK. Activities carried out wholly at overseas universities (e.g. research collaborations or transnational education arrangements) do not require registration.

Political Influence tier

Individuals and organisations are required to register under the political influence tier if they are directed by a foreign power to carry out, or arrange for others to carry out, political influence activities in the UK.

A foreign power is any of the following:

• The sovereign or other head of a foreign State.
• A foreign government (including a ministry, department or agency or local government).
• The governing political party of a foreign government.

Entities owned or controlled by a foreign power such as state-owned universities, laboratories or research institutes are not considered foreign powers if they are acting in a non-state capacity.

Political influence activities include communications, public communications or the provision of money, goods or services, where they are intended to influence any of the following:

• An election or referendum in the UK.
• A decision of a minister or government department.
• The proceedings of a UK-registered political party (such as their manifesto commitments).
• A member of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament or Senedd Cymru (when acting in their capacity as such).

Political influence activities in the research and higher education sector could include:

• Communications with senior civil servants and ministers in a government department with the intention of influencing education policy.
• Appearance at select committees or other parliamentary activities which provide information to MPs or peers.
• The publication of an article which encourages support for a Private Member’s Bill, without stating that the publication was directed by a foreign power.
• The presentation of research outcomes and associated policy proposals to senior civil servants

Arrangements under the political influence tier must be registered within 28 calendar days of the arrangement being made. Activities may take place within that 28-day window without prior registration. The maximum penalty for failure to comply with the requirements of the political influence tier is 2 years' imprisonment.

The Enhanced tier

Individuals and organisations are required to register under the enhanced tier if they are directed by a specified foreign power or entity to carry out, or arrange for others to carry out, a broader range of “relevant activities” in the UK. Specified foreign power-controlled entities are also required to register any “relevant activities” that they carry out themselves in the UK.

At the current time, the UK government has specified that the state of, and certain organisations from, Iran and Russia are within the scope of the Enhanced tier. 

Registration requirements only apply where there is a “direction” from a specified foreign power, or specified foreign power-controlled entity, to act.

Relevant activities in the context of higher education could include:

Registration of arrangements under the enhanced tier is required within 10 calendar days of the arrangement being made, and before activities are carried out. It is an offence to carry out relevant activities under a registerable arrangement without the arrangement being registered first. The maximum penalty for failure to comply with the requirements of the enhanced tier is 5 years imprisonment.

Exemptions

There are several exemptions from registration including:

• Activity where a UK Crown body or UK public body (including UKRI) is also a party to the same arrangement (both tiers).
• Any public communication activities (including research publications) where it is clear that the activity has been made at the direction of a foreign power (political influence tier). Published research which is intended to influence a political process would not require registration under the political influence tier if it was clear in the published output that it was completed as part of an arrangement with a foreign power. Registration may still be required under the Enhanced tier, if carried out at the direction of a specified foreign power or specified foreign power-controlled entity.
• Where a specified foreign power is providing an individual with financial assistance while they are completing a course of further or higher education in the UK (Enhanced tier)
• Legal activities carried out by a lawyer (both tiers).
• Philanthropic funding where there is no direction or requirement to undertake a specific activity (both tiers).

Full summaries of the exemptions can be found in the government guidance specifically for universities and researchers. 

Who to contact

If you have any concerns about FIRS, or would like advice about the registration requirements please contact the REO Due Diligence team: reo-due-diligence@essex.ac.uk

Please contact the REO Due Diligence team: reo-due-diligence@essex.ac.uk if you become aware of anything that brings a research project within the scope of FIRS registration