Guidance

Guidance on information notices issued under the Foreign Influence Registration Scheme (accessible version)

Published 1 April 2025

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Any enquiries regarding this publication should be sent to us at FIRS@homeoffice.gov.uk

About this guidance

The Foreign Influence Registration Scheme (FIRS) is a two-tier scheme which ensures transparency of foreign influence in UK politics and provides greater assurance around the activities of certain foreign powers or entities that may pose a risk to the UK’s safety and other interests. It is contained within Part 4 of the National Security Act 2023.

The scheme enables the Government to issue information notices to those in scope of the scheme. Recipients of information notices will be required to provide the information set out in the notice by the specified date.

This guidance sets out details about information notices issued under FIRS, including who can be issued with information notices and the offences of failing to comply with notices. It is intended for those who may be in arrangements registerable under the scheme, or carrying out activities pursuant to these arrangements.

Chapter 1: Introduction to information notices

1. An information notice is a request for information pertaining to a registerable arrangement or activity under FIRS. Recipients of information notices are legally obliged to respond by the date specified on the notice.

2. An information notice does not necessarily imply that the recipient is suspected of a criminal offence, or is doing anything undesirable. Those who comply with these notices are supporting the resilience of the UK and its institutions in the face of state threats.

3. The issue of an information notice has no impact on the carrying out of activities. The activities may continue to take place while a response to the information notice is being prepared.

4. Failure to comply with an information notice, without a reasonable excuse, is a criminal offence. It is punishable by:

a. Up to 5 years imprisonment and a fine under the enhanced tier;

b. Up to 2 years imprisonment and a fine under the political influence tier.

Chapter 2: Who can be issued with an information notice?

5. Sections 75(1) and (2) of the National Security Act 2023 sets out that the Government may issue an information notice to any of the following:

• Those who have registered under either tier of FIRS;
• Those who are believed to be party to an arrangement which is required to be registered under either tier of FIRS;
• Those who are believed to be carrying out (or arranging for others to carry out) activities which are required to be registered, or which are pursuant to an arrangement which is required to be registered, under either tier of FIRS.

6. For those who have registered, an information notice may be issued to those who have provided insufficient detail in their registration (for example, where it is not clear what type of activity they are involved in or what they are seeking to achieve) or where additional detail is needed to provide full transparency about the registerable arrangement or activities.

7. Information notices cannot be issued to those who are known to benefit from an exemption, such as foreign diplomatic missions, but can be issued to those to whom an exemption may or may not apply to establish whether or not this is the case.

8. If you believe that you have been issued an information notice in error, because you are not party to any registerable arrangement or carrying out or arranging registerable activities, you should contact the FIRS case management. You should provide a clear explanation as to why you believe that the notice was issued in error.

Chapter 3: Information required through an information notice

9. An information notice will specify the required information, as well as the date by which the information must be provided.

10. An information notice may require further details of the arrangement or activities which are being carried out. This could include:

• Evidence of the arrangement (including correspondence or a formal contract);
• Information about the parties of the arrangement;
• Any other information to ensure full transparency about registerable activities or arrangements (including financial statements, correspondence, meeting/event invitations or agendas).

11. Where an information notice requires information which will be published on the public register, this will be clearly indicated on the notice.

12. Where information is required that falls outside of the information included on the public register, such as financial statements, then this information will be handled in accordance with the Data Protection Act 2018 and UK General Data Protection Regulation, and will not be included on the public register.

13. Information notices do not require the recipient to provide information which they are entitled to refuse to disclose in legal proceedings on grounds of legal professional privilege (in Scotland, confidentiality of communications). Similarly, they will not be required to disclose confidential journalistic material (as defined by section 264 of the Investigatory Powers Act 2016) or to identify or confirm a source of journalistic information (as defined by section 263 of the Investigatory Powers Act 2016).

Chapter 4: Process for receiving and responding to information notices

14. The FIRS Case Management Team within the Home Office is responsible for administration of the Scheme, and for issuing information notices.

15. The method in which a response should be submitted will be specified on the notice.

16. The date by which a response is required will also be set out on the notice. This date will be at least 5 working days from the date that the notice is issued.

17. In addition to formal information notices and where appropriate, the Case Management Team may also contact registrants on a more informal basis to seek clarification about information provided at registration.