Policy paper

Foreign Influence Registration Scheme factsheet

Updated 19 August 2024

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Summary

• The Foreign Influence Registration Scheme (FIRS) is a two-tier scheme which strengthens the resilience of the UK political system against covert foreign influence and provides greater assurance around the activities of certain foreign powers or entities that are a national security risk. As a result, the UK will be better informed about the nature, scale and extent of foreign influence in UK.

• FIRS will require the registration of arrangements to carry out political influence activities in the UK at the direction of a foreign power. The enhanced tier of FIRS gives the Secretary of State the power to require registration of a broader range of activities for specified countries, parts of countries or foreign government-controlled entities where this is necessary to protect the safety of interests of the UK.

• A “direction” is an order or instruction to act. This could also be delivered in the language of a request, but only where there is a power relationship between the person and the foreign power which adds an element of control or expectation, for example through a contract, payment, coercion or the promise of future compensation or favourable treatment.

• Foreign powers themselves do not have to register, only those in arrangements with foreign powers. The UK continues to welcome open and transparent engagement with and on behalf of foreign governments. This scheme will play a critical role in encouraging transparency, while simultaneously deterring foreign powers that wish to pursue their aims covertly.

• The scheme contains a number of exemptions to ensure its proportionality, including for recognised news publishers (political influence tier only), legal activities carried out by a lawyer, diplomats and their family members and those in an arrangement to which the UK is party.

• Detailed guidance will be provided ahead of the scheme’s requirements coming into force.

The scheme’s requirements

• In line with similar international schemes, registrations will be made through an online portal.

• Failure to register when required to do so will be a criminal offence. There are also criminal offences associated with carrying out activities which are pursuant to arrangements which have not been registered.

• FIRS does not prevent any activity from taking place. Providing the arrangements are transparent, related activities will proceed as normal.

• Certain information registered will be made public.

Political influence tier

• This tier will require registration of arrangements to carry out political influence activities in the UK at the direction of a foreign power.

• These arrangements will need to be registered within 28 days of being made with the foreign power.

• Political influence activities include communications to senior decision makers such as UK ministers (and ministers of the devolved administrations), election candidates, MPs and senior civil servants. It also includes certain communications to the public where the source of the influence is not already clear, and disbursement of money, goods or services to UK persons for a political purpose. To be registerable, this activity has to be for the purpose of influencing UK public life, for example, elections, decisions of the government or members of either House of Parliament or the devolved legislatures.

Enhanced tier

• The scheme also contains a power to specify a foreign power, part of a foreign power, or an entity subject to foreign power control, where the Secretary of State considers it necessary to protect the safety or interests of the UK. Use of the power will be subject to Parliamentary approval.

• This tier will require the registration of:

  • arrangements to carry out any activities within the UK at the direction of a specified power or entity: the person making the arrangement with the specified body will be responsible for registration

  • activities carried out in the UK by specified foreign power-controlled entities. In these circumstances, the specified entity (not a foreign power) will be responsible for registration

• Where appropriate, the government may narrow the activities requiring registration under this tier. This will allow the requirements to be tailored to the risk posed by the foreign power or entity being specified.

Exemptions

The following will not be required to register with the scheme:

• Those acting pursuant to an arrangement to which the UK is party (for example, those invited to participate at an event by a UK government department) (both tiers)

• individuals acting for a foreign power in their official capacity as employees (both tiers)

• individuals to whom privileges and immunities apply in international law as provided by, for example, the Vienna Convention on Diplomatic and Consular Relations (both tiers)

• family members who are part of the household of members of diplomatic and consular staff (both tiers)

• those providing essential services to a diplomatic mission or consulate e.g., catering or building services (enhanced tier)

• lawyers providing legal services (both tiers)

• domestic and international news publishers (political influence tier only)

Any arrangement with the Republic of Ireland will also be exempt from registration.

There is no requirement to register information that is subject to legal professional privilege or would involve the disclosure of confidential journalistic material or sources.

Frequently asked questions

What information will be required at registration?

The information required from a registrant will include a description of the activities to be undertaken including their nature, purpose and any sought outcomes, details of the start and end dates of the activities, a description of the frequency of the activities, details of the individuals or entities carrying out these activities and details of the specified entity or foreign power who is directing the activities.

Will information registered under the scheme be made public?

Some information will be available to the public online. The government intends to limit this to what is necessary to achieve the transparency aims of the scheme.

Certain personal details related to individuals, such as full date of birth and address, will be withheld from publication in order to protect their privacy.

Information will not be published in any of the following circumstances:

• where there is a risk that publication would prejudice the national security of the UK
• where there is a significant risk that publication would put any individual’s safety at risk
• where publication would involve the disclosure of commercially sensitive information

What constitutes “direction” by a foreign power or specified entity? Will funding by a foreign government constitute “direction”?

The ordinary meaning of “direction” is an order or instruction to act. This could be delivered in the language of a request, but only where there is a power relationship between the person and the foreign power which adds an element of control or expectation to the request, for example through a contract, payment, coercion or the promise of a future compensation or favourable treatment.

It is not enough for a foreign power to fund an activity. Generic requests, joint collaboration, or simply an alignment of views, absent this power relationship, will not meet the test for direction.

Ownership, or part-ownership by a foreign power (for example, in the case of a state-owned enterprise), does not necessarily mean that activities are directed by a foreign power.

Detailed guidance on what constitutes direction will be published in advance of the scheme coming into force.

How will the scheme be enforced?

A scheme management unit will be established within the Home Office which will have both administrative and investigative functions.

Information notices can be issued to request more information about registered arrangements or activities, or where the Secretary of State reasonably believes that an arrangement or activity should have been registered.

Where it is believed that a criminal offence has taken place, the scheme management unit will pass relevant information onto law enforcement.

Is this a register of foreign spies?

No. This is a common misperception with similar schemes.

Registering with the scheme does not mean that an individual is a spy or that they are engaged in undesirable or unlawful activity and there will be no automatic requirement to cease or alter this arrangement.

What is the difference between FIRS and the National Security and Investment Act 2021?

The National Security and Investment Act 2021 gives the government powers to scrutinise and intervene in business transactions, such as takeovers, to protect national security, while providing businesses and investors with the certainty and transparency they need to do business in the UK. The Act requires organisations to notify and seek approval from the government for certain acquisitions of an entity in 17 specific areas.

FIRS requires the registration of particular activities or arrangements in order to strengthen the integrity of UK politics and institutions and protect the country from state threats. FIRS does not require that activities or arrangements must be approved before they can take place. The scheme requires the registration of:

• arrangements with foreign powers to carry out political influence activities, and

• activities by specified entities in the UK or arrangements with specified foreign powers or entities to carry out activities in the UK

Will FIRS affect academic collaboration?

Academic collaboration will only require registration if it involves political influence activities directed by foreign powers, or if activities are directed by a country or state-controlled entity that the Secretary of State specified in regulations because they believe greater transparency is necessary to protect the safety or interests of the UK.

Even if registration is required, this will not mean that academic and research collaborations require approval before they can take place.

Will FIRS affect charities’ ability to campaign on political issues?

Charities will only need to register if they are directed by a foreign power to conduct political influence activities, or if their activities are directed by a country or state-controlled entity that the Secretary of State specified in regulations because they believe greater transparency is necessary to protect the safety or interests of the UK.

Where charities operate independently and act pursuant to their own private aims, they will not be required to register.

Even if registration is required, this will not mean that charities require approval for their activities.

Will FIRS affect freedom of expression?

The scheme will have no impact on people’s right to express their views, nor will it prevent anyone from engaging in political influence activities.

It simply requires openness and transparency around such activities where undertaken at the direction of a foreign power.