Foreign Influence Registration Scheme (FIRS)

On 1 August 2025, the UK Government introduced the Foreign Influence Registration Scheme (FIRS). This is part of the National Security Act 2023.

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What is it?

FIRS is designed to ensure transparency around foreign influence on public life, particularly in terms of political influence. It is a registration scheme, not an approval scheme. Provided arrangements are registered, they can proceed without restriction.

There are potential criminal penalties for non-compliance, so it is important that we understand our obligations.

Two types of activity must be registered:

1. Political influence

Arrangements directed by foreign powers (except the Republic of Ireland) to conduct political activities in the UK must be registered within 28 calendar days of the direction being given.

An ‘arrangement’ could be formal (such as a contract), informal (such as an MOU), arise from a payment or a verbal agreement.

‘Powers’ are heads of state, overseas governments (including arms or agencies of governments), a localised authority of a foreign state or a political party where it is the ruling party.

Political influence activities are those designed to influence a political matter in the UK - including elections, government decisions, political party or individual parliamentarians.

Examples could include

  • communications directly with government ministers, MPs, election candidates and some other senior public officials inviting them to take a certain stance on a policy, investment etc.
  • giving money, goods or services to a UK national or organisation to influence an outcome or to gain influence
  • communicating publicly, for example, through newspaper articles or social media unless it is clear which foreign state it is on behalf of

As a charity, the University must operate within the law and guidance from the Charity Commission. Charities can take part in political activity provided it supports their purpose and is in their best interests. The University’s purpose, set out in its Charter, is to advance education through teaching and research. As an organisation, we would not expect to undertake political lobbying outside of our direct interests, and it is extremely unlikely we would seek to do so as directed by a foreign power. 

Individual members of staff are not bound by the same guidance where they are speaking in an individual capacity. The FIRS requirements apply both to organisations and to individuals. Staff are required to register individually in the case of private arrangements to undertake political influence directed by foreign powers.

2. Enhanced Tier activities

The enhanced tier encompasses a wider set of activities directed by specified foreign powers - currently Iran and Russia, but this is subject to change.

Registration is required to carry out any activity in the UK directed by these foreign powers. Activity cannot begin before it has been registered and registration must be within 10 calendar days of an arrangement being agreed.

There are specified powers and entities for both countries (including political entities and armed forces, intelligence services etc). There is a list on the UK government website.

Entities owned or controlled by a foreign power, for example, state-owned universities, labs or research institutes, are not considered foreign powers by virtue of this ownership. So arrangements with state owned universities to undertake research would not require registration by Sheffield.

There are some exemptions which are helpful from the perspective of UK HE:

  • Funded education arrangements - this covers international students in the UK on Russian and Iranian Government scholarship programmes. The exemption applies to activities relating to the students’ course of study and any related progress reports to the funder, but not all activity - eg a student may be directed by a foreign power to organise a campus protest. The student would be responsible for registering this.
  • Arrangements which are part of multi-lateral arrangements where a UK public body such as UKRI is included.

What do I need to do?

FIRS is legislation so we do not have a choice whether to comply.

If you are undertaking activities as part of your University employment which you think falls under one of the two tiers, please contact the following individuals for advice and for support with registration.

If you are undertaking activities as a private citizen, the legislation applies to you. Information on how to register is on the UK Government website.

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