Foreign Influence Registration Scheme
Introduction
The Foreign Influence Registration Scheme (FIRS) Link opens in a new window came into effect on 1 July 2025. Contained within the National Security Act (2023), it applies to all individuals and organisations operating in the UK, including universities. It is intended to promote transparency about the intervention of foreign powers in public activities in the UK. Where a party is conducting activity subject to FIRS, which is conditional on what they are being directed to do and by which entity, they are required to register the activity with the Home Office.
FIRS is a two-tier system consisting of a Political Influence Tier and an Enhanced Tier.
Practicalities & Responsibilities
State-owned companies, universities and individual state actors acting in a non-state capacity are not within the scope of FIRS.
The requirement is only to register. It is not a system of approval. Once registration is completed then the activity may commence. It must not start before registration is completed.
All departments within the University will be required to have processes in place to manage FIRS requirements and will be expected to manage their own processes.
Departments will also need to conduct a one-off review of live activities which will need to be declared retrospectively. There is a grace period from 1 July to 1 October 2025 permitted for this. R&IS are preparing to review live research projects to capture any need for registrations within this time frame.
There is a need to educate and raise awareness of FIRS across the University communities, especially to those individuals (students and researchers) who may be most at risk not only of conducting activities where the University may need to register, but also of individually needing to register under FIRS.
The university would not be held liable for circumstances where arrangements are made without their knowledge or involvement, for example:
• Where a registerable arrangement is formed by an individual academic in their own name (for example, private research or consultancy work): The academic is responsible for registration;
• Where a registerable arrangement is formed by a spinout company formed of academics from a university: The spinout company is required to register;
• Where a registerable arrangement is made by a subsidiary of the university: The subsidiary is required to register;
• Where a registerable arrangement is made by a student society of a university: The society is required to register.
FIRS assessment in R&IS
Formal arrangements under FIRS which relate to research activities will be assessed during the research due diligence process. The pre-award team will liaise with the lead academic to establish whether a registerable arrangement exists, and the Research Governance and Compliance team will work with the lead academic to collect the information required for online registration:
• Description of the nature and form of the arrangement
• Name of the foreign power directing the activity
• Description of the activities to be undertaken including nature, purpose and sought outcomes
• Details of the start and end dates of the activities
• Details of individuals or entities who will carry out activities
• Details related to registrant (including address and contact details)
Once the arrangement has been registered, a pdf copy of the registration form will be sent to the lead academic.
What if my research is unfunded or informal?
Agreements made as part of unfunded or informal research which would not normally pass through the R&IS office should also be considered and registered if relevant. The RG&C Team are available to discuss further and guide academics through the registration process. Contact us on
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