NTE 2025/19: Foreign Influence Registration Scheme launch - guidance on registering foreign power arrangements

BY:

Niamh O'Connor
14 July 2025

SHARE:

The Home Office has released Notice to Exporters 2025/19, publishing details on when and how you must register with the Foreign Influence Registration Scheme, or FIRS

The new scheme originates from the National Security Act 2023, which received Royal Assent in July 2023, with implementation by the FIRS from 1 July 2025.


Registration of an event becomes necessary when a UK organisation or person finds itself under the direction or influence of a foreign state or foreign government body.


Definitions are given within the guidelines to enable a clear assessment of when to register such influencing direction or activity.


Definitions:

A definition of a ‘direction’ from a specified foreign power or a foreign power-controlled entity can be identified as being formally given by contract, for example, or informally, such as in a quid pro quo arrangement


The definition of ‘relevant activities’ has a default meaning that encompasses all activities, including, but not limited to, commercial activities, the provision of goods and services, research activities, and attendance at events.


Exemptions are in place for certain activities. These are given in the guidance documentsA link is provided later in this document.

Registration of any relevant foreign influence activity is obligatory as it relates to the safety and interests of the UK.


When to Register with the Foreign Influence Registration Scheme (FIRS)

There are 2 types of activity that may need to be registered under the FIRS scheme: the Political Influence tier and the Enhanced tier, as follows:


Political influence tier:

Registration is necessary if you are instructed by a foreign power to carry out, or arrange for others to carry out, political influence activities in the UKDetails from the guidance are as follows:

The political influence tier requires individuals or organisations to register where they are directed by any foreign power (except the Republic of Ireland) to carry out, or arrange for someone else to carry out, political influence activities in the UK.


A foreign power includes:

  • the sovereign or other head of a foreign State,
  • a foreign government, or part of a foreign government (for example, a ministry or department of a foreign government);
  • an agency or authority of a foreign government, or of part of a foreign government (for example, a police force or military of a foreign government),
  • an authority responsible for administering the affairs of an area within a foreign country or territory (for example, a local government authority in a foreign country);
  • a political party which is a governing political party of a foreign government.


Political influence activities include communications made to senior public officials or politicians (for example, emails or meetings), public communications (for example, the publication of an article) or disbursements (for example, the provision of goods or services) which are intended to influence one of the following:

  • An election or referendum in the UK
  • A decision of a Minister or Government department (including a Minister or Government department of Wales, Scotland, or Northern Ireland);
  • The proceedings of a UK-registered political party (such as their manifesto commitments);
  • A Member of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament, or Senedd Cymru


Enhanced tier – relating to Russian or Iranian influences

Registration is necessary if you are instructed by the Russian or Iranian state to carry out, or arrange for others to carry out, ‘relevant activities’ in the UK

The enhanced tier requires:

  • Individuals or organisations to register where they are directed by a specified foreign power or specified foreign power-controlled entity to carry out, or arrange for someone else to carry out, “relevant activities” in the UK;
  • Specified foreign-power controlled entities to register any “relevant activities” that they carry out themselves in the UK.


Details of the foreign powers and entities which have been specified on the enhanced tier for Iran and Russia can be found at the link below:

Foreign Influence Registration Scheme specified powers: Iran - GOV.UK

Foreign Influence Registration Scheme specified powers: Russia - GOV.UK


Further information and links to the legislation and guidance:

A link to the legislation can be found here:

National Security Act 2023


Provision for the Registration scheme within the legislation can be found here:

National Security Act 2023

To find out more and whether you need to register, read the FIRS guidance and FIRS business-specific guidance.



If you have further queries, contact the FIRS General Enquiry Desk at the following link:

 firs-general-enquiries@homeoffice.gov.uk.

Focus On: Embargoes, Sanctions and End-Use Controls

This half-day session highlights the importance of understanding embargoes and sanctions, focusing on UK regulations and the growing sanctions on Russia. It reviews current financial sanctions managed by OFSI and the severe consequences of non-compliance, including fines, reputation loss, and criminal charges. The course emphasises the need for exporters to comply with embargoes and sanctions. It identifies areas where companies can unintentionally become non-compliant, such as end-use, end-user, and transit codes.

Focus On: Preparing for an Export Control Audit

Trading goods worldwide can expose companies to greater risk & cost in the form of lost goods or unnecessary delays or disputes. The simple allocation of responsibilities in the supply chain can help, which is what Incoterms® Rules have been doing since 1936. Generally, Incoterms® are misunderstood and frequently misused; ensure you are using them correctly by joining us on this full-day interactive course.



The UK Export Licensing System

This course combines the key elements of the UK Export Licensing System into a practical session. By reviewing the UK strategic export control lists and the legislation surrounding financial sanctions, delegates will gain a comprehensive foundation of knowledge to support future learning and understand internal requirements.



Beginners Guide to Export Licensing Controls

Whether at the start of your learning pathway or as a standalone training session, this course will begin your journey to understand export licensing controls and how they work. Covering essential elements gives delegates an excellent springboard to understand what goods, technology or software could be controlled and review business-relevant areas in more detail.


OneCall™ Email assistance as and when required; A one-call solution for all your import, export and customs enquiries. Export help. Import help. Customs help.

Stay informed about customs and international trade matters by subscribing to our OneCall™ service. This comprehensive offering includes a dedicated email helpline for support, timely practical updates direct to your inbox (Did You Know?), monthly UK Customs & Trade Briefings and access to an interactive members' area with an exclusive community for our subscribers.

Subscribe Today ➝

International Trade Updates & Spotlight Newsletter

Subscribe to our free information emails covering international trade topics...

Subscribe to our newsletter ➝

MORE INDUSTRY INSIGHTS...

by Andy Baker 10 July 2025
For Businesses that are established within GB (England, Scotland, Wales), you may need to use the Safety and Security GB service to submit your ENS declarations.
by Niamh O'Connor 10 July 2025
HMRC have published Notice to Exporters 2025/18 detailing a compound settlement made by a UK exporter for breaches of UK export control conditions to Russia.
by Gail Leeson 8 July 2025
The Department of Business and Trade have published Preferential Origin and Quota documentation that will support the use of the US-UK Economic Prosperity Deal when importing beef and ethanol from the United States. The General Terms of the agreement were finalised on the 8 th May this year.
Show More