Westminster Watch: The Foreign Influence Registration Scheme

The Foreign Influence Registration Scheme (FIRS), introduced by the last government under the National Security Act 2023, creates a new statutory transparency regime requiring the registration of certain UK‑based activities carried out by any type of lobbyist, consultant, or other adviser at the direction of foreign powers. It is overseen by the Home Office. The scheme is intended to increase visibility of state‑linked foreign influence, strengthen public confidence and protect UK national interests. Importantly, FIRS establishes a compliance and disclosure framework rather than prohibiting activity. It applies broadly to individuals, companies, partnerships, charities, NGOs and other organisations operating in the UK.

FIRS came into force last summer, with mandatory registration in specified circumstances (outlined below) from 1 October 2025. However, as highlighted in a recent Financial Times article, the scheme is gaining prominence as the UK Government considers expanding its scope to certain Chinese state-owned entities under the enhanced tier (see below).

 

FIRS operates through two tiers: 

1. Political Influence Tier: Applies to arrangements with any foreign power that involve carrying out political influence activities in the UK. 

2. Enhanced Tier: Applies to arrangements with specified higher-risk foreign powers or entities they control – Russia and Iran only – and captures a far broader range of activities beyond political influence.

Where the four conditions for registration under the political influence or enhanced tiers are met, it is the individual or organisation which is in the arrangement with the foreign power that is required to register.

 

Political Influence Tier

Condition 1: An "arrangement" is made with a “foreign power”, where:

• examples of "arrangement", whether formal or informal, include but are not limited to a contract, non-legally binding agreement such as Memorandum of Understanding or even a quid pro-quo agreement; and
• "foreign power" covers a broad range of state-linked actors such as the head of a foreign state, a foreign government or any part of it (such as a ministry or department), agencies or authorities operating under that government, bodies administering regional or local areas within a foreign country, and any political party that forms the governing party of a foreign government.

Condition 2: The arrangement involves a “direction” from that foreign power, where:

• "direction" means an informal or formal order or instruction with which a person is obliged or compelled to comply with.

Condition 3: The direction is to carry out “political influence activities” in the UK, whether by the registrant or with or through someone else, where:

• "political influence activities" are activities meeting the following two-tier criteria:

Criterion 1: The activity must involve:

• communicating (eg email, letter, meeting) with a senior official or politician;
• making a public communication (eg an article) that is not clearly labelled as directed by a foreign power; or
• providing money, goods or services to a person or organisation in the UK (eg providing consultancy services to a UK business).

Criterion 2: The activity must be intended to influence:

• a UK election or referendum;
• a ministerial or government decision;
• the actions of a UK political party; or
• the work of MPs and devolved legislators.

Examples:

YES

• Envoy in an arrangement with a foreign power to promote the idea of a free trade agreement between the UK and Country X to a UK Minister.
• Consultant in an arrangement with foreign power to carry out activities to convince the UK Government to grant visa-free status for nationals of Country A who are visiting the UK.
• Charity in an arrangement with a foreign power to arrange for a wildlife expert to influence a UK political party’s manifesto commitments.

NO

• A charity is provided funding by a foreign power, but its political influence activities are not directly connected to the conditions of the funding.
• Lobby firm in an arrangement with a private foreign business to influence the UK Government to relax regulations affecting their sector.
• Think tank in an arrangement with a multilateral organisation to propose policy recommendations to the UK Government at a conference.

Condition 4: No statutory exemptions apply. Applicable statutory exemption include:

• foreign officials acting in their official capacity (such as diplomatic or consular staff) as well as their family members supporting official duties;
• lawyers providing legal services to foreign powers;
• recognised domestic and international news publishers; and
• sovereign wealth or public pension funds undertaking influence activities linked to UK investments.

 

Enhanced Tier

Condition 1: An "arrangement" is made with a “specified foreign power and entity”, where:

• the same definition of "arrangement" as set out above applies; however
• specified foreign power and entity, currently, means only Russia and Iran as well as specific state-linked bodies in those countries as set out in relevant regulations (here and here).

As noted above, the UK government is considering designating selected Chinese state‑linked bodies (rather than China as a whole) under the enhanced tier.

Condition 2: The arrangement involves a “direction” from the specified foreign power or entity, where:

• the same definition of "direction" as set out above applies.

Condition 3: The direction is to carry out “relevant activities” in the UK, whether by the registrant or with or through someone else, where:

• "relevant activities" mean all activities in the UK, including but not limited to, commercial activities, research activities and the provision of goods and services.

Condition 4: No statutory exemptions apply. These are broadly similar to exemptions under the Political Influence Tier. However, there are some additional exemptions:

• the supply of goods or services necessary for the operation of diplomatic or international missions in the UK;
• activities connected to funded education arrangements, such as scholarships; and
• routine governmental administrative or technical services, including matters like passports and visas.

 

Is every single activity registerable?

No. Importantly, it is the arrangement, not each individual activity under it, that must be registered. Registrants must keep their registrations current, notify the Home Office of material changes within the required timeframes, and respond to information notices.

 

Registration deadlines:

• Political Influence Tier: Arrangements must be registered within 28 days of the arrangement being entered into.
• Enhanced Tier: Arrangements must be registered within 10 days of the arrangement being made and before activities commence.

 

Public Register and Disclosure:

The FIRS public register is accessible via the GOV.UK portal (here), providing a searchable record of registered foreign-influence arrangements and functioning as the UK’s equivalent of a foreign agents register (comparable to regimes in jurisdictions such as the US and Australia).

However, disclosure is limited. Information may be withheld on grounds of national security, commercial confidentiality, and personal safety, meaning that only a restricted subset of registrations will be publicly visible.

 

Offences and Penalties 

Non-compliance with FIRS constitutes a criminal offence, with penalties determined by the applicable tier, which also carries potential reputational and financial risks.

• Political Influence Tier: Up to 2 years’ imprisonment and/or an unlimited fine
• Enhanced Tier: Up to 5 years’ imprisonment and/or an unlimited fine

While certain offences are subject to knowledge-based thresholds and statutory defences, these protections depend on demonstrable compliance frameworks. In practice, enforcement risk is likely to extend beyond intentional breaches to include deficiencies in governance, controls, and record-keeping.

 

Recommended Approach

FIRS should be treated as a compliance regime comparable to sanctions or export controls. Even where an organisation has no political intent, routine commercial or academic engagement can trigger registration if it is directed by a relevant foreign power or specified entity. The regime is dynamic, and the list of designated foreign powers and entities may expand over time, requiring organisations to keep their relationships and activities under continual review. Keep a particular eye on the potential for future designation of Chinese state-entities by the UK Government. Best practice includes:

• Map foreign-state touchpoints – identify relationships with governments, state-owned enterprises, and political parties.
• Assess “direction” early – document who initiates and controls activities and whether they could fall within scope.
• Implement governance and training – ensure relevant teams understand triggers, exemptions and record-keeping requirements.
• Monitor developments – track new designations and guidance to reassess existing arrangements.
• Prepare for registration – establish internal processes for timely filings, updates and responses to Home Office information notices.

DLA Piper would be pleased to assist your organisation with bespoke FIRS scoping and risk assessments, advice on registrability, registration strategy and filings, policy design and training, and engagement with the Home Office where required.

For further information, please contact a member of the Trade and Government Affairs (TGA) team at DLA Piper. We also invite you to attend a forthcoming webinar to be hosted on 20 April, with the session delivered by Paul Hardy, Head of the TGA team at DLA Piper, and members of the Home Office team responsible for FIRS. The webinar will provide practical guidance on the FIRS regime. Registration link is available here.