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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 documents. A 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 UK. Details 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:
Provision for the Registration scheme within the legislation can be found here:
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:
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