What to Know About the New UK Foreign Influence Registration Scheme, launching on 1 July 2025

On 1 April 2025, the UK government announced that the Foreign Influence Registration Scheme (“FIRS”), as introduced under the National Security Act 2023 (“NSA 2023”), will come into force on 1 July 2025.

Headlines

• As previewed in our previous updates on 24 October 2022 and 9 August 2023, the FIRS introduces a two-tier registration system for individuals and organisations involved in UK political influence activities on behalf of “foreign powers” (which includes all non-UK heads of state, foreign governments or parts of foreign governments, agencies or authorities of foreign governments, or foreign governing political parties). The two tiers are: (1) the political influence tier; and (2) the enhanced tier. The political influence scheme captures arrangements with all foreign powers but only applies to limited political influence activities. The enhanced tier only applies to arrangements with specific foreign powers that have been identified by the UK Secretary of State, but it captures a broader range of activities including most commercial and research activities.
• The UK government has published detailed guidance on how organisations and individuals can comply with the FIRS, which includes sector-specific guidance for the business, media, academia, charities, and defence sectors, with detailed scenarios demonstrating examples of arrangements requiring (or not requiring) registration under the political influence tier. Separate guidance has been produced for the enhanced tier.
• Non-compliance with the FIRS registration requirements is a criminal offence. For the political influence tier, offences are punishable by up to two years’ imprisonment and/or fines. For the enhanced tier, offences are punishable by up to five years’ imprisonment and/or fines.
• The FIRS significantly expands previous efforts to regulate lobbying activities in the UK, which to date have applied only to activities by external lobbyists. Organisations and individuals that have historically fallen outside existing regulations and other industry frameworks may now have to consider FIRS registration requirements. PR firms, think tanks, and even private, multinational companies may now need to register their activities and could face additional scrutiny, albeit only in the context of arrangements involving directions from foreign powers.
• There are a limited number of exemptions to the FIRS registration requirements. For instance, news publishers that hold a licence under the Broadcasting Act 1990, sovereign wealth funds, and public pension funds (which fulfil certain criteria) are exempt from registration under the political influence tier; and diplomatic family members and lawyers carrying out legal services are exempt from registration under either tier.

Political Influence Tier

Under the political influence tier, unless an exemption applies, individuals and organisations must register if they enter into an agreement or arrangement of any sort pursuant to which they are directed by a foreign power to carry out certain “political influence activities” in the UK.

 “Political influence activities” capture communications to a senior UK public official or politician, public communications or the provision of money, goods, or services to an entity or individual in the UK, which aim to influence: (i) a UK election or referendum, (ii) a decision from a UK minister or a government department, (iii) the proceedings of a UK registered political party, or (iv) a UK Member of Parliament.

Enhanced Tier

Under the enhanced tier, an individual or organisation will need to register (i) any agreement/arrangement (ii) with a specified foreign power or foreign power-controlled entity (iii) to carry out any activity (the precise scope of captured activities can be modified by the UK Secretary of State) at their direction. As such, the enhanced tier applies to a narrower set of foreign powers/controlled entities in comparison to the political influence tier, but the type of activities that require registration are far broader.

The UK government has so far announced that Iran and Russia (alongside certain of their respective controlled entities) have been specified under the enhanced tier. While there are speculations as to whether China should be specified under the enhanced tier, no formal announcement in this regard has been made yet. The UK Secretary of State can place any additional foreign powers on the enhanced tier for national security reasons.

Registration and Enforcement

Individuals and organisations that are parties to agreements/arrangements in scope of the FIRS (i.e., not the foreign power/controlled entity) have the obligation to register the nature and form of the agreement/arrangement under one of the two tiers, including the name of the foreign power/controlled entity directing the activity.

Registration will also require a description of the activities, including their nature, purpose and sought outcomes, timeframes, and the individuals or entities who will carry out the activities. Subject to limited exceptions, the register will be open for public inspection.

The timeframes for registration are set out in the table below. 

Enforcement of the FIRS will be under the purview of the UK Home Office, with a FIRS Management Unit responsible for administration and investigation. The FIRS Management Unit will refer criminal cases to UK law enforcement if necessary.

Next Steps

The FIRS has potentially wide impacts. Organisations that do not benefit from an exemption and have touchpoints with foreign powers should undertake a risk assessment to identify their arrangements or agreements with foreign powers and then consider whether, in connection with those agreements or arrangements, the organisation undertakes any activities that may trigger the FIRS registration requirements. Organisations should also consider whether any exemptions may apply. The UK government’s sector-specific guidance provides worked examples of certain exemptions, and organisations should consider these in parallel when making an assessment as to whether their arrangements or agreements with foreign powers trigger any FIRS registration requirements. Organisations with connections to Iran and Russia should pay particular attention to the scope of the enhanced tier of the FIRS. Where appropriate, firms should start preparing to register relevant activities before the applicable deadline.

Organisations impacted by the FIRS should update their compliance policies to ensure ongoing compliance with the FIRS and implement training to ensure employees and others working for the organisation are familiar with the scheme and alert to the risks of non-compliance.

If you have any questions, please contact the authors of this alert.