The Foreign Influence Registration Scheme Goes Live 1st July
The government have announced that FIRS will go live from 1st July this year.
The good news is that the government have given the three months’ notice the university sector requested.
The bad news is that’s ONLY three months’ notice.
What is FIRS?
The Foreign Influence Registration Scheme (FIRS) was introduced by the last Conservative government as part of the National Security Act 2023. The idea behind FIRS is that by making certain arrangements transparent, particularly foreign money influencing political activities, the mechanics of UK democracy would benefit. A little sunshine disinfects everything.
The Scheme requires registration of certain activities (it doesn’t prohibit anything; just mandates disclosure) many of which will end up on a publicly accessible register.
Citizens and journalists can look at the register to uncover motives behind political statements, for example.
How does it work?
There are two main arms of FIRS:
The Political Influence Tier
The “Enhanced” Tier
If caught under either Tier, the individual or organisation will need to use a government portal to provide certain details of the arrangement. Once the details are submitted, the requirements of the Act are met; there’s no need to wait for any kind of clearance.
The Political Influence Tier
The Political Influence Tier requires individuals and organisations to register details of arrangements they enter into with foreign powers which direct them to undertake political influence activities in the UK.
There are exceptions; many of which don’t apply to the university sector.
The truth is - in my view - universities are unlikely to enter into arrangements with a foreign power where that foreign power directs the university to undertake political influence activities. There will be plenty of arrangements where there is an arrangement with a foreign power (e.g. to fund a research project) and the university subsequently does undertake political influence activities (e.g. publishing policy papers to influence government policy) but the important factor is that this is unlikely to be at the direction of that foreign power. To do so would be an affront to academic freedom, if nothing else.
Universities with foreign power funded cultural institutes, such as Confucius Institutes, are likely to need to register them as their activities will necessarily involve political influence activities.
Still, universities must now spend three months auditing their entire organisations to check for arrangements that might meet the criteria under the Political Influence Tier.
The Enhanced Tier
The Enhanced Tier, in law, gives extremely broad discretion for the government to specify other foreign powers or foreign entities with whom any activity at all is registerable, or (if they wish) the government can choose to specify more limited set of activities for specific foreign powers or foreign entities.
Until today we’ve not known much about what the government will do with the Enhanced Tier - they had earlier said that Iran would be named as a foreign power with whom every arrangement will be registerable.
There has been a big question over China - and strong views from both sides lobbying for their inclusion or not as a specified foreign power, either for all activities or for certain specified activities1.
Well, for the time being at least, that question is answered. China - for now - is not included.
To begin with, all activities with Russia, and all activities with Iran, will fall under the Enhanced Tier2.
It’s slightly more subtle than this as specified entities are set out in the regulations; for example, it’s not just “Russia” and so whoever is responsible for FIRS registration in your organisation will need to understand that list.
What do universities need to do now?
The number one challenge is information; how do you ensure that whoever is responsible for registering arrangements is made aware of all activities that need to be registered?
A high level statement from a Vice Chancellor or similar should go out to all staff that tells them they need to inform a central mailbox about all activities that fall within the political influence tier, and all arrangements with Russia or Iran.
In my view, individuals should not be encouraged to apply any of the exemptions themselves3; those should only be applied by an internal FIRS compliance expert. The exemptions are easily misunderstood. So all arrangements should be disclosed internally, but the individual disclosing it can note if they think an exemption is applicable.
Some kind of internal disclosure form should be set up now - this can be done with something as simple as Microsoft Forms or the Google equivalent. It should capture, in one form, all information required for registration.
Comms should go out to all Schools/Faculties highlighting requirements to register all arrangements with Russia or Iran.
Research funding databases should be searched to check any arrangements with foreign governments, and from that search Principal Investigators can be sent a message to inform the university if at any point they are directed to undertake political influence activities.
It’s likely most universities will have no, or extremely limited, activities with the Russian and Iranian governments, but you can’t take this for granted and it needs to be verified.
I would also suggest reviewing the government guidance on FIRS (which is quite good!) including the academic and research sector guidance available here.
Biggest Worries
Just as a bonus, here would be my biggest worries if I was an in-house university lawyer:
Students - Student Unions may need to register, and may not know they need to register.
Academics - Academics often wear lots of hats - they may have personal consultancy arrangements, or have another job at a think-tank. Often there is a blurring of roles and an implication that the activities is being undertaken via the university.
China - I don’t think this question is over yet. The Enhanced Tier will almost certainly change and I would be looking at where information is stored in the organisation regarding arrangements with China and making plans to gather info if/when the Enhanced Tier changes.
Yes, for 1. and 2. technically the onus for registering is not on the university - and the penalties (which include 5 years in prison) won’t fall on the university. But the press article about the lack of registration will almost certainly name the university.
Conclusions
Universities need to act NOW and act fast.
Firstly, who is responsible for FIRS registration and compliance? Being clear on responsibility will ensure it doesn’t fall between the cracks.
Understanding the registration requirements (i.e. what info do you need to register) and formulating internal information capture routes (online forms) is key.
Comms need to go out to all staff with a clear position on what staff must declare.
1st July will come round very quick!
I suppose it’s ironic that we’ll never know how much lobbying was done with money from the Chinese government
Subject to approval from parliament which will almost certainly whizz through
The exemptions are also likely to change, see this draft instrument: https://www.legislation.gov.uk/ukdsi/2025/9780348270754/contents I’m still working my way through this, but see the part about scholarships which mentions ATAS