The UK Foreign Influence Registration Scheme Launches on 1 July 2025

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Overview

The Foreign Influence Registration Scheme (“FIRS”) comes into force on 1 July 2025 and is contained in Part 4 of the National Security Act 2023 (the “Act”). FIRS is being introduced to ensure transparency of foreign influence in the UK with the aim of protecting the UK’s safety and interests.

FIRS is a two-tier scheme, made up of a political influence tier and an enhanced tier. The scheme requires individuals and organisations to register “foreign activity arrangements” and “foreign influence arrangements” entered into by them with foreign powers and persons specified by the Secretary of State in regulations.

Registration can be completed on FIRS online registration service, which will be live from 1 July 2025.

Political influence tier

The political influence tier aims to increase transparency of foreign power influence in UK political affairs.

A person or organisation is required to register under the political influence tier when all of the below four conditions (“Conditions”) are met:

1. A person or organisation makes an arrangement (whether formal or informal) with a “foreign power”;
2. The arrangement involves a “direction” from the foreign power;
3. The direction is to carry out “political influence activities” in the UK (whether by the registrant, or with or through someone else); and
4. No exemptions apply to the arrangement or activities.

Condition 1: For the purposes of the Act, an arrangement can include, but is not limited to, a contract, a Memorandum of Understanding or an informal quid pro quo agreement.

The term “foreign power” is defined under the Act to encompass a head of state, a foreign government, an agency of a foreign government, a local government authority and a governing political party.

Condition 2: A “direction” is an order or instruction to act with which a person is obliged or compelled, whether formally or informally, to comply. A request from a foreign power may be considered a direction if, for example, there is an element of control, coercion, or benefit to be received. There needs to be a link between such a direction and Condition 3 (the political influence activity) for this Condition 2 to be fulfilled.

Condition 3: A “political influence activity” has to satisfy two criteria set out in the Act. First, the activity must constitute (i) a communication to a senior public official or politician; (ii) a public communication; or (iii) the provision of money, goods or services to an entity or individual in the UK. Second, the purpose of the activity must be to influence a UK election or referendum, a decision from a minister or a government department, the proceedings of a UK registered political party, or a member of Parliament (when acting in their capacity as such).

Condition 4: There are a number of exemptions to the political influence tier that are set out in the Act, for example - individuals acting for foreign powers in their official capacity as employees, lawyers providing legal services to foreign powers, and with respect to domestic or international news publishers (subject to qualifying requirements).

Enhanced tier

The enhanced tier seeks to provide greater assurance around the activities linked to certain foreign powers.

The enhanced tier requires registration of relevant activity in the UK where a person or organisation is acting at the direction of specified foreign powers or foreign power-controlled entities. It also requires specified foreign power-controlled entities to register relevant activities that they carry out themselves in the UK. Unlike the political influence tier, registration under the enhanced tier is only required for agreements or arrangements with (a) foreign powers, or (b) organisations acting on behalf of foreign powers (“Specified Persons”), that are specified by the Secretary of State in regulations. Specified Persons under the enhanced tier are currently limited to those from Russia and Iran.

A person or organisation is required to register under the political influence tier when all of the below four conditions are met:

1. A person or organisation makes an arrangement (whether formal or informal) with a “foreign power”;
2. The arrangement involves a “direction” from the foreign power;
3. The direction is to carry out “relevant activities” in the UK (whether by the registrant, or with or through someone else); and
4. That no exemptions apply to the arrangement or activities.

The conditions above are the same in most part as the Conditions for the political influence tier, except for condition 3, which references “relevant activities”. Unless otherwise stated, relevant activity means any activity in the UK and potentially overseas activities that have an effect in the UK; this includes commercial activities, research activities and the provision of goods and services (subject to exemptions).

Russia

The Russian entities that are currently specified under the enhanced tier of FIRS include the President of Russia; the Government of Russia and all of its agencies and authorities; the Federal Assembly of Russia; the judiciary of Russia; the United Russia Party; the Communist Party of Russia; the Liberal Democratic Party of Russia; and the A Just Russia Party.

Iran

The Iranian entities that are specified under the enhanced tier of FIRS are the Supreme Leader of Iran; the Government of Iran and all of its agencies and authorities; the Islamic Consultative Assembly of Iran; and the judiciary of Iran.

Registration

Arrangements made prior to FIRS coming into force and completed by 1 July 2025 do not need to be registered. Ongoing arrangements entered into before FIRS comes into effect and continuing thereafter must be registered by 1 October 2025.

It is important to note that registration under the political influence tier and the enhanced tier have different deadlines:

• For “foreign influence arrangements” under the political influence tier, registration must take place within 28 calendar days, beginning on the day the arrangement is made;
• For “foreign activity arrangements” under the enhanced tier, any new arrangements must be registered within 10 calendar days from the date on which the agreement or arrangement was made and prior to any activities pursuant to the arrangement being carried out.

Failure to register in accordance with the Act is a criminal offence. A conviction for such an offence can result in up to two years in prison and/or a fine under the political influence tier and up to five years in prison and/or a fine under the enhanced tier.

Next steps

Given the broad nature of FIRS, it may not always be clear where registration is required and anyone involved in arrangements with foreign powers and their representatives should consider registering such arrangements in compliance with the Act and seek qualified advice.

Businesses should consider adopting policies, procedures and training to ensure that relevant arrangements are identified in time and registered in compliance with the Act.