Foreign Influence Registration Scheme (FIRS)

The Foreign Influence Registration Scheme (FIRS) was introduced in part 4 of the National Security Act 2023 and registration will start on 1st July 2025. 'FIRS will 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.' (gov.uk)

The Scheme applies to all staff and students and is not limited to research or research-related activities.

Please review the guidance carefully to ascertain if your specific scenario, arrangement, or activity requires registration, is exempted, or does not otherwise require registration. This is a registration process only and there is no approval of any registered activities required or implied in the registration process.

Failure to comply is an offence with maximum penalties of up to 5 years imprisonment.

 

*We will continue to update this page as more information becomes available on the implications of the Scheme for researchers and the online registration process.* 

Please contact compliance-support@gla.ac.uk with any queries on research-specific aspects of FIRS.

Two Tiers (Political Influence / Enhanced)

The Scheme consists of two tiers (text adapted from UK Government FIRS guidance): 

  • the political influence tier: individuals and organisations are required to register under the political influence tier if they are directed by a foreign power (except the Republic of Ireland) to carry out, or arrange for others to carry out, political influence activities in the UK. Information provided will appear on a public register after review by the FIRS team.  There are a few exemptions to publication which may be requested as part of the registration process.
  • the enhanced tier 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, Russia and Iran]. Specified foreign power-controlled entities are also required to register any “relevant activities” that they carry out themselves in the UK. Information registered under the enhanced tier will not be published, unless the arrangement relates to, or includes, the carrying out of political influence activities. In these circumstances, the information which is to be published will align with that which is published under the political influence tier
  • Where an arrangement is registerable under both the enhanced tier and the political influence tier, registration under the enhanced tier only is required.  

Under both tiers, registration is required by the individual or organisation who makes the registerable arrangement with the foreign power, specified foreign power or foreign power-controlled entity. It is the arrangement that must be registered, not each individual activity that will be carried out. Other individuals or organisations involved in carrying out the activities under a registerable arrangement should check that the arrangement is registered prior to carrying out the activities. 

Timelines (Go Live 1 July 2025)

  • Go Live - 1 July 2025
  • 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.
  • Arrangements under the enhanced tier must be registered 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. 
  • Existing arrangements as of 1 July 2025 must be registered by 1 October 2025. 
  • Registrants are required to update their registration within 14 days where there is a material change to any of the information that they have provided.

Exemptions

There are exemptions, covered in the guidance, which include scholarship funding and where UK public bodies (such as the NHS or UKRI) are party to the agreement or arrangement. You will need to review the guidance for the relevant tier to confirm whether your activity is covered under the exceptions or whether you must register.

Activity is also only registerable where carried out in the UK, meaning that any activities carried out wholly at overseas universities (as may be the case with some research collaborations or transnational education arrangements) would not require registration.

As of 18 June 2025, the exemptions from registration listed in the academia-specific guidance apply to:

  • UK Crown body arrangements (both tiers)

  • foreign powers acting overtly (both tiers)

  • diplomatic family members (both tiers)

  • legal activities carried out by a lawyer (both tiers)

  • recognised news publishers (political influence tier only)

  • sovereign wealth funds carrying out investment-related activities (political influence tier only)

  • activities that are reasonably necessary to support diplomatic missions (enhanced tier only)

  • UK public body arrangements (enhanced tier only)

  • certain funded education arrangements (enhanced tier only)

  • certain government administrative services (enhanced tier only)

 

 

Outline of Conditions for Registration

Registration is required when all 4 conditions are met

Political Influence tier

  • Condition 1: A person makes an arrangement (whether formal or informal) with a “foreign power”.

  • Condition 2: The arrangement involves a “direction” from the foreign power.

  • Condition 3: The direction is to carry out “political influence activities” in the UK (whether by the registrant, or with or through someone else).

  • Condition 4: That no exemptions apply to the arrangement or activities.

Enahnced Tier

  • Condition 1: A person makes an arrangement (whether formal or informal) with a specified foreign power or entity.

  • Condition 2: That arrangement involves a “direction” from the specified foreign power or entity.

  • Condition 3: The direction is to carry out “relevant activities” in the UK (whether by the registrant themself, or with or through someone else).

  • Condition 4: That no exemptions apply to the arrangement or activities.

 

Registration

More information will be provided as it becomes available

How to register online

Information required to register

Responsibility for Registration: (adapted from guidance at link)

73. Where the conditions for registration under either tier of FIRS are met, it is the individual or organisation which is in the arrangement with the foreign power (political influence tier) or specified foreign power or entity (enhanced tier) that is required to register.

74. Therefore, where a university forms a registerable arrangement with a foreign power, it is the university as an entity that has the legal responsibility to register.

75. A university would not be held liable for circumstances where arrangements are made without their knowledge or involvement, for example:

  • where a registerable arrangement is formed by an individual academic in their own name (for example, private research or consultancy work): the academic is responsible for registration

  • where a registerable arrangement is formed by a spinout company formed of academics from a university: the spinout company is required to register

  • where a registerable arrangement is made by a subsidiary of the university: the subsidiary is required to register

  • where a registerable arrangement is made by a student society of a university: the society is required to register

Whilst arrangements could be made by academics using their university email address, and activities may be carried out on a university campus, this does not in itself transfer responsibility for registration onto the university.

Where a university is in a registerable arrangement, the registration form may be completed by any employee of the university. In these circumstances, the personal details of one officer of the university are required. This officer should be a member of the senior management of the university, such as a vice-chancellor. They do not necessarily need to be the same individual as the one completing the form. These details are collected for the purpose of ID verification, to ensure that a registration is not being made fraudulently in the name of someone else or another organisation.

Individual academics or researchers who are involved in carrying out activities that they reasonably know are pursuant to a registerable arrangement formed by the university should check to see whether the university has registered the arrangement before carrying out activities. This can be done by requesting a confirmation of the registration from the registrant which can then be verified by contacting the FIRS Case Management Team.