The UK’s forthcoming Foreign Influence Registration Scheme

Updated 10 June 2025

The UK’s Foreign Influence Registration Scheme (“FIRS”) will come into force on 1 July 2025. In recent years, a rapidly polarised global geopolitical landscape has provided an added impetus for consecutive Government’s to bolster the United Kingdom’s approach to national security.

As part of The National Security Act 2023, FIRS was introduced as a mechanism to protect the safety and interests of the UK through mandating the disclosure of foreign influence activity occurring within this country at the instruction of a foreign state or particular foreign state-controlled organisations.

You can read more about the background to FIRS in our May 2024 Insights Article.

Key Requirements at a Glance

• FIRS is a two-tier registration scheme that will apply to both individuals and organisations (“Registrants”). Arrangements to carry out political activities in the UK at the direction of foreign powers must be registered.
• Registration, if required, can be completed on the FIRS online registration service. Certain information regarding any relevant agreement will need to be included at the time of registration, including parties’ details and the activities delivered as part of the agreement. You can learn more about the online registration process here, and the information required when registering, here.
• FIRS does not make it illegal for a Registrant to conduct political influence activity at the instruction of a foreign state or to conduct activity at the instruction of a foreign state or organisation (specified by the enhanced tier). But, to do so, registration is necessary within the required timeframe.
• The registration process is intended to promote transparency: an agreement only needs to be registered once, outlining separate activities as necessary. If an agreement comes within the scope of both tiers it should be registered under the enhanced tier.
• There is a three-month grace period to register existing arrangements already in place on 1 July 2025 and continuing in effect (which come within the scope of FIRS under either tier). By 1 October 2025, any ongoing arrangements made before 1 July 2025 should be registered.
• FIRS has a broad scope and non-compliance could result in criminal liability, reputational damage, and commercial challenges arising from potentially greater regulatory scrutiny. Below, we include some information regarding non-compliance and the resulting criminal liability; this is non-exhaustive as there are various punishable offences under FIRS.
• The Home Office has published further industry / sector-specific guidance, in relation to academia and research, business, charities and civil society, defence and security, and, media, providing tailored information for potential Registrants to assess the extent to which their activities trigger FIRS obligations.

The Two-Tiers

Political Influence Tier:

• Unless exempted, a Registrant must register, within 28 days, details of a "foreign influence arrangement".
• A "foreign influence arrangement" is a formal or informal arrangement made with a "foreign power" (broadly defined to mean non-UK heads of states, governments or local governments, government agencies or authorities, or political parties) where a relevant party is "directed" by the foreign power to arrange for, or carry out, political influence activities in the UK. Generally, forming an arrangement with an employee of an entity constituting a foreign power, acting in this capacity, will be treated as forming an arrangement with the “foreign power”.
• "Political influence activities" must involve (i) an activity - either a communication with the public (for example, through a social media post), or senior public officials (including MPs, ministers and electoral candidates), or the provision of money, goods or services to UK persons, and (ii) the purpose must be to influence UK public life, including political decisions, elections, referendums or registered political parties.
• An organisation which has the legal responsibility to register will face criminal liability for non-compliance. Generally, criminal liability will fall upon the organisation rather than the individual who completed the registration form; however, there are certain circumstances in which an officer of a company could be liable for the actions of the company (see sections 35 and 81(1) of the National Security Act 2023).
• Penalties for non-compliance: up to two years' imprisonment and/or unlimited fine.
• Exemptions from registration apply to: foreign powers acting overtly (e.g., diplomats acting in their official capacity, diplomatic family members supporting the work of a diplomat); lawyers conducting legal activities; recognised news publishers; sovereign wealth funds and public pension funds carrying out political influence activities in relation to their investments; arrangements where the UK is a party and arrangements directed by the Republic of Ireland.

Enhanced Tier:

• Unless exempted, registration is required within 10 days of formal or informal arrangements made with a "specified foreign power or entity" (currently, those from Iran and Russia), where an individual / entity is "directed" by the specified foreign power or entity to arrange for, or carry out, "relevant activities" (currently defined as all activities, but subject to the Government narrowing the scope) in the UK. Generally, forming an arrangement with an employee of a specified foreign power or foreign power-controlled entity, acting in this capacity, will be treated as forming an arrangement with a specified foreign power or entity.
• Activity must not begin until registration is completed.
• An organisation which has the legal responsibility to register will face criminal liability for non-compliance. Generally, criminal liability will fall upon the organisation rather than the individual who completed the registration form; however, there are certain circumstances in which an officer of a company could be liable for the actions of the company (see sections 35 and 81(1) of the National Security Act 2023).
• Penalties for non-compliance: up to five years' imprisonment and/or unlimited fine.
• Exemptions from registration apply to: foreign powers acting overtly (e.g., diplomats acting in their official capacity, diplomatic family members supporting the work of a diplomat, those providing goods / service supporting the work of a diplomat); lawyers conducting legal activities; government administrative and technical services; those in an arrangement in which a UK crown body or UK public body is a party; those carrying out activities related to funded study arrangements.

Compliance and Obligations to Provide Information

The Home Office’s FIRS Case Management Team has a broad administrative and investigative remit, including to:

• Maintain the online registration service and live public register (the “Public Register”), (including assessing whether an exception to publication applies (as explained further below));
• Conduct quality checks of information provided by Registrants as part of the registration / material change update process as well as contact Registrants for clarification as necessary;
• Issue an Information Notice (“Information Notice”) where appropriate, as explained further below;
• Relay information about potential criminal offences to relevant law enforcement.

The Case Management Team will not approve or reject registrations. Once an in-scope arrangement has been registered, the relevant activities may commence or continue.

Registration Process and the Public Register

FIRS is intended to improve transparency regarding the scale and degree of foreign influence in the UK and particularly, within UK political affairs. As such, information which relates to political activities will be published in the Public Register, once it has been processed by a FIRS caseworker.

The Public Register is updated on a regular basis so registrations are made public as soon as reasonably practicable. Given the transparency aims of FIRS, the information on the Public Register will be limited to that which is relevant to the in-scope arrangements or activities.

Information is retained on the Public Register for 10 years from the stated end date of the arrangement or otherwise indefinitely, where an end date has not been provided. The Case Management Team has discretion to review published information and decide whether it should be removed from the Public Register.

Exceptions

Certain information will be withheld from publication where:

1. there is a risk that publication would prejudice UK national security or safety;

2. there is a risk the publication would prejudice the prevention or detection of crime, a criminal investigation or criminal proceedings;

3. there is a significant risk that publication would jeopardise an individual's safety;

4. publication would involve the disclosure of commercially sensitive information.

Registrants can apply to request that their information is withheld from publication, as part of the registration process. Required information and supporting documentation must be submitted within five working days of registration. Exceptions to publication can apply to the registration as a whole, or only part of the registration, where relevant information is within scope of an exception.

What does the registration process look like?

This article has been amended to reflect information about the FIRS registration process, identified through our experience in Beta testing the FIRS online registration portal (the “Platform”). The Beta testing closed on 6 June 2025. As such, although the final version of the Platform might vary slightly from the version we have seen, we expect the scope for changes to be minimal.

• At the start of the registration process, a Registrant must identify the person whom they have appointed as Senior Responsible Officer (“SRO”). The SRO will need to verify their identity using the Platform and create a FIRS account number, before any registration process can proceed to submission. An SRO:
  (i) is responsible for ensuring compliance with FIRS within an entity;
  (ii) is typically a senior executive within the entity;
  (iii) has the authority to make decisions about FIRS; and,
  (iv) is the single point of contact for the FIRS Team.
• A Registrant will be required to input information about the entity they represent, including the entity’s incorporation date, incorporation location and address, as recorded for companies at Companies House.
• When describing an arrangement or activity, a Registrant may either be required to make a selection from a list of dropdown options or complete a free-text information box.
• Registrants are able to review and amend entries prior to submission.
• The Platform interface allows Registrants to (i) manage Registrant information and multiple registrations; (ii) review FIRS Guidance; and, (iii) submit queries directly to the FIRS Case Management Team.

More information is available in this FIRS Guidance: registration and public register.

Information Notices

Under FIRS, the Government may issue an information notice to those within scope of the scheme – those who have registered, are required to be registered, or are carrying out arrangements / activities which are required to be registered under either tier of FIRS.

A notice may be issued in various circumstances, including when the Case Management Team deems that a Registrant has provided insufficient detail in their registration or where, to ensure full transparency about the registerable arrangement or activities, further information is required from them.

A recipient of an information notice is legally obliged to respond by the specified date (at least five working days from the date on which the notice is issued) and include the required information.

It is a criminal offence to fail to comply with a notice, without a reasonable excuse, punishable by: (i) under the political influence tier, up to two years’ imprisonment and a fine; (ii) under the enhanced tier, up to five years' imprisonment and a fine.

What are the broader implications of FIRS?

The introduction of FIRS in the UK parallels and expands upon similar models introduced in the United States (through its Foreign Agents Registration Act) and Australia (through its Foreign Influence Transparency Scheme Act).

In the UK’s evolving regulatory landscape, FIRS is a harbinger of a new approach to protecting national interests. Greater rigour and scrutiny will be applied to monitor and manage risk associated with foreign relationships and influence activities over UK commercial and political affairs.

FIRS’s extensive scope will have far-reaching impacts. Particular concerns include:

• The broad scope of "directed", which is undefined in the National Security Act 2023 and therefore may refer to a formal direction from a foreign power (such as by means of a contract) or an informal direction from a foreign power (such as through a quid-pro-quo arrangement). Notably, there are several circumstances under which a "request" from a specified foreign power or entity could also be considered a direction.
• The lack of an exemption for "legitimate commercial activities" - this is a notable difference from both the American and Australian regimes.
• The list of the "specified foreign powers or entities" is subject to change at the discretion of the UK government. While overlap with foreign regimes subject to sanctions can be expected, it is also possible that government bodies of nations with which Britain conducts a great deal of trade could be included, in particular China. This could introduce a significant compliance burden for UK entities which, in the long-term, could result in a reduction in business, given associated costs.
• The implications of the publicly-accessible FIRS Register on commercial activity and the ability to maintain business relationships, where counterparties may be concerned about confidential commercial information being subject to public scrutiny. While there are limited circumstances under which exception to publication can be claimed, this process will have cost implications and at least until the system is well-established, uncertainty as to what specific information will be exempted.
• The resource and financial burden to ensure effective compliance - notably, associated with the requirement to register existing "political arrangements" and "enhanced tier arrangements" within a three month period, as well as to monitor ongoing business activity to ensure new arrangements are registered within the requisite 10 or 28 days period (as set out above) and that material changes are registered within the requisite 14 day period.

What should you do next?

Prior to the obligations under FIRS taking effect on 1 July 2025, there are four key actions that affected entities should consider:

1. Contribute to the development of the scheme by joining the Home Office’s research panel to improve the online registration service or by providing feedback regarding the FIRS guidance.

2. Monitor further developments and any announcements over the next three weeks closely, regarding changes to FIRS such as any changes to, or additional guidance and any changes to which foreign powers are included in the "enhanced tier" as a result of global geopolitical pressure.

3. Proactively prepare to meet the narrow compliance window by conducting a risk assessment across operations and supply chains, to identify current and future activities/arrangements that could come within the scope of FIRS. Refresh internal policies, processes and training as necessary to ensure potential registrable arrangements are processed efficiently through appropriate procedures and approvals.

4. Develop an approach to reduce the compliance burden from a resource perspective and consider whether the cost of compliance can be transferred to customers or clients whose activities may require registration. It may be necessary to develop a screening system to classify and assess arrangements which could be subject to registration requirements and standardise processes to register, provide material updates and, where necessary, apply for information to be withheld from publication. It may be appropriate to include provisions in contracts that pass along some or all of the internal costs associated with conducting diligence and the registration process (though there is no registration fee) and to allow the UK entity to terminate a contract without notice or penalty if a material change brings the business activity within the scope of FIRS.

Please contact us at Simmons & Simmons LLP should you have any questions, or if it would be useful to discuss the potential implications of this regime, more broadly.