On 1 April 2025, the UK Government announced that a new Foreign Influence Registration Scheme (“FIRS”) — established pursuant to the National Security Act 2023 (the “NSA”) — will launch with effect from 1 July 2025. The Government also published extensive practical guidance regarding the implementation of FIRS.
FIRS is intended to provide greater transparency regarding foreign influence in UK politics and other activities involving foreign powers or persons that may present a risk to the safety or interests of the United Kingdom. This alert briefly summarizes the scope of FIRS, explains its current status, and outlines the implications and next steps for persons subject to a FIRS registration requirement.
The Scope of the Scheme
Based on long-running concerns regarding perceived gaps in the legal framework applicable to foreign influence activities in the UK, the UK Government indicated its openness to new registration measures in 2019. Initially, the Government was expected to adopt a modified version of the US Foreign Agents Registration Act or the Australian Foreign Influence Transparency Scheme Act, both of which are focused exclusively on political influence activities. The final version of FIRS is similar to the US and Australian regimes in some respects, as it includes a registration requirement for political influence activities directed by foreign powers. However, FIRS goes beyond the US and Australian measures, as it also introduces a registration requirement for certain other non-political activities conducted in the UK at the direction of specified foreign powers or entities. We summarize the political influence registration requirement and the enhanced registration requirement below.
Political Influence Registration Requirement
When FIRS enters into force, any person who is party to an agreement or arrangement with a foreign power to carry out or arrange political influencing activities in the UK at the direction of that foreign power will be required to register within 28 days of the date of the agreement or arrangement. For these purposes:
- The term “foreign power” will include: the sovereign or head of state of a foreign state in their public capacity; a foreign government or part of a foreign government; an agency or authority of a foreign government or of part of a foreign government; an authority responsible for administering the affairs of an area within a foreign country or territory, or persons exercising the functions of such an authority; or a political party which is a governing political party of a foreign government. (The Republic of Ireland is specifically excluded from this definition.)
- The term “political influence activity” will include the following activities, when those activities are conducted for the purpose of influencing a UK election or referendum, a decision of a UK or devolved government department or minister, the proceedings of a UK registered political party, or a UK legislator acting in their official capacity:
- communicating with a wide range of specified public officials, including ministers in the UK Government and devolved administrations in Wales, Scotland and Northern Ireland; members of the UK parliament or devolved legislatures; employees of members of the UK parliament or devolved legislatures; the Mayor of London and certain other UK local government officials; officers, trustees or agents of UK registered political parties; members of UK registered political parties who are exercising executive functions on behalf of such parties; certain UK election candidates; senior UK civil servants and special advisers; certain senior UK military officers; certain senior UK police officers and police commissioners; and any other persons exercising UK public functions who are identified by the Home Secretary in regulations;
- making a public communication — including publishing or disseminating information, a document or other article, or producing information, a document or other article for publication or dissemination — except where it is reasonably clear from the communication that it is made by or at the direction of the foreign power; and
- distributing money, goods or services to UK persons.
There will be some very limited exceptions to the political influence registration requirement, including with respect to the carrying out of certain legal activities by a qualified lawyer, and with respect to some activities relating to news publishers.
Enhanced Registration Requirement
In addition to the political influence registration requirement, FIRS will establish an enhanced registration requirement relating to certain “specified persons”. In summary:
- Specified persons, as well as their employees, will be prohibited from carrying out any “relevant activities” in the UK unless the specified person registers those activities with the Home Secretary. The “relevant activities” concept potentially includes all activities in the UK conducted by a specified person, although it will also be possible for the Home Secretary to take a less expansive approach and require only certain activities of a specified person to be registered. The intention is that this will allow the Government to tailor the registration requirement to the risk posed by the specified person.
- In addition, if a person enters into an agreement or arrangement with a specified person pursuant to which the specified person directs that other person to carry out relevant activities in the UK, or to arrange for relevant activities to be carried out in the UK, the agreement or arrangement must be registered within 10 days of the date of the agreement or arrangement. This obligation would rest with the person entering into the agreement or arrangement with the specified person, rather than with the specified person itself. The definition of “relevant activities” summarized above would also apply in this context.
For these purposes, the Home Secretary is authorized to designate as a “specified person” any foreign power or entity that she reasonably believes to be controlled by a foreign power, if she considers it reasonably necessary to do so to protect the safety or interests of the UK.
Last month, the Government confirmed that certain Iranian entities would be designated for this enhanced tier. The announcement on 1 April 2025 confirms that the Government also intends to designate certain Russian entities to the enhanced tier. Guidance and draft regulations for Iran and Russia, respectively, set out the “specified persons” and “relevant activities” at issue:
- For Iran, the following persons will be designated as specified persons: the Supreme Leader of Iran; the Government of Iran and all of its agencies and authorities, including the Supreme Leader’s Office, the Assembly of Experts, the President, the Office of the President, the Guardian Council, all ministers, all ministries, the Expediency Council, the armed forces (including Artesh and the Islamic Revolutionary Guard Corps), the Supreme National Security Council and its subcommittees, any other intelligence services, and all police forces; the Islamic Consultative Assembly of Iran; and the judiciary of Iran. Any activity in the UK at the direction of a specified person — including commercial, media, charitable, and academic/research activity — will be captured by the designation.
- For Russia, the following persons will be designated as specified persons: the President of Russia; the Government of Russia and all of its agencies and authorities, including the Presidential Executive Office, the Security Council, the State Council, all ministers, all ministries, the armed forces, the Federal National Guard Troops Service, the Federal Security Services, any other intelligence services, and the government of a federal subject of Russia; 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. As for the Iranian designations, any activity in the UK at the direction of a specified person — including commercial, media, charitable, and academic/research activity — will be captured by the designation.
There has previously been speculation that Chinese state entities could also be added to the list of specified persons, and the Conservative Party committed to doing so during the UK General Election in 2024. This continues to be Conservative Party policy and, in the House of Commons debate following the announcement of the 1 July 2025 launch date, the Shadow Home Secretary said that there was “no question” that China should be included within the scope of the enhanced registration requirement. Responding to that call, the Government minister refused to speculate on which countries may or may not be specified in the future. However, he also indicated that the current Government’s approach towards China is arguably more nuanced than the prior Government’s approach: “The Government’s policy is clear: we will cooperate where we can, compete where we need to and challenge where we must, including on issues of national security.”
As with the political influence registration requirement discussed above, there are some very limited exceptions to the enhanced registration requirements.
Offences
The NSA also establishes several criminal offences relating to FIRS and its operation.
Current Status
As noted above, the registration requirements under FIRS will apply from 1 July 2025. However, there will be a grace period for registrable agreements or arrangements in place prior to 1 July 2025. In particular, registrable agreements or arrangements that were made prior to 1 July 2025 but continue on or beyond that date must be registered by 1 October 2025. Agreements or arrangements made prior to 1 July 2025 that have completely ceased by 1 July 2025 do not need to be registered.
Implications and Next Steps
Any person who is party to an agreement or arrangement with a foreign power to carry out or arrange political influencing activities in the UK at the direction of that foreign power should begin preparations to register the agreement or arrangement, if relevant activities will continue on or beyond 1 July 2025.
Likewise, any person who is party to an agreement or arrangement with a specified Iranian or Russian person pursuant to which the specified person directs that other person to carry out any activities in the UK should begin preparations to register, if any activities will continue on or beyond 1 July 2025.
In addition, given the risk of criminal liability for persons involved in registrable activities while unregistered, entities that are involved in such agreements or arrangements should consider adopting policies, procedures and training to ensure that relevant activities are identified by their employees and registered in a timely manner.
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