Foreign Influence Registration Scheme (FIRS)

The political influence tier of FIRS will apply if you have an arrangement with any foreign power (except the Republic of Ireland) to carry out political influencing activities in the UK.

The enhanced tier of FIRS may apply if you have arrangements in place for conduct of activities with specific foreign powers or foreign power-controlled entities as set out in the regulations. At present, this applies to the States of Iran and Russia (and certain entities in those countries).

The scheme’s requirements are split into two tiers:

• the political influence tier, which requires the registration of arrangements with any foreign power (except the Republic of Ireland) to carry out political influence activities in the UK
• the enhanced tier, which requires the registration of arrangements to conduct a wider set of activities but only with the foreign powers or foreign power-controlled entities which have been specified in regulations. At the current time, this applies to arrangements with the States of Iran and Russia, and certain entities in those countries

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Individuals and organisations are required to register under the political influence tier if they are directed by a foreign power to carry out, or arrange for others to carry out, political influence activities in the UK.

A foreign power is any of the following:

• the sovereign or other head of a foreign State,
• foreign government (including a ministry, department or agency or local government)
• governing political party of a foreign government

Entities owned or controlled by a foreign power (e.g. state-owned universities, laboratories or research institutes) are not considered foreign powers

Registration requirements only apply where there is a “direction” from a foreign power to act.

Political influence activities include certain communication activities, public communication activities or the provision of money, goods or services, where they are intended to influence any of the following:

• an election or referendum in the UK
• a decision of a minister or government department
• 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 (when acting in their capacity as such)

Political influence activities in the research, academia and higher education sector could include:

• communications with senior civil servants and ministers in a government department which seek to influence education policy
• appearance at select committees and other parliamentary activities, which provide information seeking to influence MPs or peers
• the publication of an article which encourages support for a Private Member’s Bill, without stating that the publication was directed by a foreign power
• the presentation of research outcomes and associated policy proposals to senior civil servants

Arrangements under the political influence tier must be registered within 28 calendar days of the arrangement being made. Activities may take place within that 28-day window without prior registration.

The maximum penalty for failure to comply with the requirements of the political influence tier is 2 years' imprisonment.

Individuals and organisations are required to register under the enhanced tier if they are directed by a specified foreign power or entity to carry out, or arrange for others to carry out, a broader range of “relevant activities” in the UK. Specified foreign power-controlled entities are also required to register any “relevant activities” that they carry out themselves in the UK.

At the current time, the UK government has specified that the state of, and certain organisations from, Iran and Russia are within the scope of the enhanced tier. 

Registration requirements only apply where there is a “direction” from a specified foreign power, or specified foreign power-controlled entity, to act.

“Relevant” activities in the context of higher education could include:

• hosting an event or conference in the UK at the direction of a specified foreign power or specified foreign power-controlled entity
• undertaking a research project directed by a specified foreign power or specified foreign power-controlled entity
• sending information from the UK to a specified foreign power or specified foreign power-controlled entity

Registration of arrangements under the enhanced tier is required within 10 calendar days of the arrangement being made, and before activities are carried out. It is an offence to carry out relevant activities under a registerable arrangement without the arrangement being registered first.

The maximum penalty for failure to comply with the requirements of the enhanced tier is 5 years imprisonment.

A number of exemptions from registration exist, including:

• Activity where a UK Crown body or UK public body (including UKRI) is also a party to the same arrangement (both tiers)
• Any public communication activities (including research publications) where it is reasonably clear that the activity has been made at the direction of a foreign power (political influence tier). Therefore, any published research which intended to influence a political process would not require registration under the political influence tier if it was clear in the research report that it was completed as part of an arrangement with a foreign power. It may still require registration under the enhanced tier, if carried out at the direction of a specified foreign power or specified foreign power-controlled entity
• Where a specified foreign power is providing an individual with financial assistance while they are completing a course of further or higher education in the UK (enhanced tier)
• Legal activities carried out by a lawyer (both tiers)
• Philanthropic funding where there is no direction or requirement to undertake a specific activity (both tiers)
• Political campaigning (e.g. by student societies or unions) unless directed to do so by a foreign power (political influence tier)

Summaries of the exemptions most likely to be relevant to academia, higher education and research sectors are set out in the guidance for higher education and the research sector.

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It is the organisation (e.g. the University or a college) or the individual who is in the arrangement that is required to register.

Where the University has entered into a registerable arrangement: the registration will be made on behalf of the University by the Trusted Research Team in Research Services. Please notify the Trusted Research Team via RSFIRS@admin.ox.ac.uk if you are aware of an arrangement that is registerable by the University.

Where a college has entered into a registerable arrangement: the college is responsible for registration

Where an individual member of staff or student has entered into a registerable arrangement in their own name (for example, private research or consultancy work): the individual is responsible for registration.

Where a spinout company formed by academics from the University has entered into a registerable arrangement: the spinout is required to register.

Where a subsidiary company of the University has entered into a registerable arrangement: the subsidiary is required to register the arrangement.

Where a student society, whether or not a registered society of the University, has entered into a registerable arrangement: the society is required to register the arrangement.

Academic visitors from a specified foreign power or entity are not required to register, unless they have been directed by the specified foreign power or entity to undertake relevant activities.

Further details about the information required at registration, and information about the public register, including the specific arrangements which will be published, are available via the government’s guidance on registration and the public register.

Further advice and information on FIRS can be obtained from the Trusted Research Team in Research Services (please contact: RSFIRS@admin.ox.ac.uk)