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Foreign Influence Registration Scheme

The UK government requires registration of foreign-influenced political or sensitive activities. All University staff and students should check whether their work falls under the remit of the Foreign Influence Registration Scheme, and take action as necessary.

The Foreign Influence Registration Scheme (FIRS) is designed to enhance transparency around foreign influence in the UK by requiring certain arrangements or activities with foreign powers to be registered with the government. Compliance with FIRS is required by law (under the National Security Act 2023), and the scheme came into force on 1 July 2025. Pre-existing arrangements which meet the criteria for registration, and which are continuing beyond that date needed to be registered by 01 October 2025.

To be clear, registering an activity or agreement does not necessarily mean that it is undesirable or illegitimate, provided they are registered they may go ahead.  

The implications of registration are that a public record of the activity or agreement is created.  This will likely involve greater scrutiny of the arrangement and the activities being conducted by government agencies, the media and the public who will all have access to the register.

The obligation to register arrangements which fulfil the criteria is a legal one and penalties for not complying include criminal prosecution, fines and even imprisonment.

IMPORTANT: The registration obligations are an ongoing requirement and any material change to the relevant arrangement (eg an amendment to a registered agreement) must be registered within 14 days.

How FIRS applies to us 

FIRS applies to “arrangements” which involve a “direction” from a foreign power or entity (broadly speaking a sovereign, government, or agency representing a government) including but not limited to:

  • Research projects
  • Funding arrangements (including teaching, conferences, external speakers)
  • Strategic relationships
  • International visitors
  • Philanthropic donations
  • MOUs
  • Informal arrangements (eg by telephone or email)

A direction from a foreign power may be given formally (such as by means of a contract) or informally (such as through a quid-pro-quo arrangement).

For some practical examples of what sort of agreements and arrangements might be covered, ,the government has provided sector-specific examples of relevant registerable and non-registerable arrangements and has published a set of questions and answers for universities.

Scheme requirements 

Institutional

When universities enter into arrangements with foreign powers, they must register such arrangements if:

Individual

When individuals enter into arrangements with foreign powers, the individual must register such arrangements if:

There are two different registration tiers under FIRS, set out below.

Political influence tier

This requires the registration of arrangements to carry out political influence activities in the UK at the direction of any foreign power or entity. 

  • A political influence activity is defined as “communication, public communication or provision of money, goods or services intended to influence a political matter”
  • New agreements must be registered within 28 days of the formal or informal agreement governing the activity being entered into 

Some examples the gov.uk site gives for political influence activities include lobbying activities on behalf of a foreign power, eg trying to persuade ministers or individual MPs to vote for an increase in student  visas for the particular country in question; communicating publicly eg writing a newspaper article or social media post and not making it clear that this is on the direction of a foreign state or on behalf of it.

Enhanced tier

This requires the registration of any activities (not just political influence activities) within the UK at the direction of a specified foreign power. Currently such specified foreign powers are Iran and Russia, subject to future changes.

  • Activity cannot begin until the formal or informal agreement governing the activity has been registered, and it must be registered within 10 days of the agreement being made.

Not all arrangements will be required to be registered and you can find a list of exemptions to registration here: FIRS guidance Enhanced Tier - Exemptions 

Advice and the registration process

All staff and students must comply with the requirements of FIRS. If you think you have already entered into an agreement or arrangement, or are about to enter into an applicable agreement then as a first step you will need to fill in this questionnaire. 

Our self-guided registration form will take you through a set of questions to determine whether your activity requires registration. Where institutional-level registration is required, you can use the form to submit the relevant information to the central team, who will register the activity on your behalf.

If you still have queries regarding your activity, please contact trusted-research@york.ac.uk (for research-related activities) or psc-admin-manager@york.ac.uk (for all other activities).

Research-related activities

FIRS guidance and registration on behalf of the institution for all research-related activities (collaborations, funding etc) will be overseen by the Policy, Integrity and Performance (PIP) Team in RIKE (contact trusted-research@york.ac.uk). 

Other activities

All other institutional activities (donations, strategic relationships, UEB-led programmes) will be supported under advice from Legal Services (contact legal@york.ac.uk)