On 1 July 2025, the UK’s new Foreign Influence Registration Scheme (FIRS) came into force, marking one of the most significant steps the UK has ever taken to strengthen transparency in its political system. Created under the National Security Act 2023, FIRS requires individuals and organisations acting on the instruction of foreign powers to register those activities.
Far beyond a simple lobbying register, FIRS is a two-tier scheme designed to shine a light on covert foreign influence, whether that influence is exerted through political messaging, commercial relationships, or even cultural engagement. If your organisation has any arrangements, direct or indirect, with foreign governments, foreign-controlled entities or even certain overseas partners, you must get to grips with FIRS, or face serious criminal liability.
For any business, NGO, public affairs consultancy, academic institution, or civil society organisation engaging with foreign states, this is a scheme that cannot be ignored.
What is FIRS?
The Foreign Influence Registration Scheme is designed to force transparency around foreign political influence and related activities. It operates on two levels:
The political influence tier
- Captures arrangements with any foreign power involving activities to influence the UK’s political system
- Covers communications with UK politicians, the public, or the provision of goods and services for political influence purposes
- Registration required within 28 days of making an arrangement
The enhanced tier
- Captures arrangements with specified foreign powers or their controlled entities (currently Iran and Russia)
- Applies to any activity in the UK directed by these foreign powers, regardless of whether the activity is political
- Registration required within 10 days and before activities begin
Failure to register with FIRS is a criminal offence, with penalties of up to two years in prison under the political influence tier, or up to five years under the enhanced tier.
What counts as “direction” for FIRS?
The scheme introduces the concept of “direction” as a key test. The Home Office defines it as an order or instruction to act, which may be framed as a request but carries an expectation due to a power imbalance, for example, because of payment, contractual obligations, coercion, or a promise of future benefits.
Simply receiving money or support from a foreign power is not direction if the recipient is free to use it as they wish. But if a foreign power says, “we will fund you if you do X,” that is almost certainly direction and triggers the registration requirement.
Political influence tier: Implications for business
For UK businesses, the political influence tier of FIRS poses a significant compliance challenge. Organisations that lobby government ministers on behalf of foreign clients, promote changes to UK legislation at the request of foreign governments, or run public relations and media campaigns in support of foreign state bodies are directly in scope.
Political influence activities under this tier can include communicating with UK ministers, MPs, or other senior decision-makers, publishing public communications such as paid social media campaigns, or providing money, goods, or services that advance a foreign power’s political objectives.
Consider a scenario in which a PR agency is contracted by a Middle Eastern government to campaign for loosening UK visa restrictions. That agency would have to register the arrangement within 28 days, as would any freelance lobbyists they bring on board to support the campaign. Activities can proceed within that initial 28-day window, but failure to register on time is a criminal offence, carrying a maximum penalty of up to two years’ imprisonment.
Enhanced tier: Implications for business
The enhanced tier casts an even wider net. It covers arrangements or activities that are directed by foreign powers or foreign power-controlled entities specifically listed by the UK government. At present, these are Iran and Russia. Unlike the political influence tier, almost any type of activity in the UK connected to these designated powers can require registration.
For example, businesses could be required to register if they host investment or promotional events for a specified foreign power, sign contracts with a Russian embassy to provide catering or hotel services, modify their UK marketing materials under pressure from a designated foreign ministry, or deliver research and consultancy projects on behalf of a specified Iranian entity. In these cases, businesses must register within 10 days of making the arrangement and before carrying out any related activities. Non-compliance with the enhanced tier rules carries even more severe consequences, with potential penalties reaching up to five years’ imprisonment.
When might your business have to register with FIRS?
✅ Joint ventures
If your UK business is part of a joint venture with a foreign entity, and the foreign partner is a specified foreign power or directed by one, registration may be triggered if the venture involves activities in the UK.
✅ State-owned enterprises
If you contract with a foreign state-owned enterprise that is under significant government direction, and the state instructs how the enterprise should act, registration could be required.
✅ Professional services
Marketing agencies, consultants, law firms, or research partners who are directed by a foreign power to promote certain messages or influence UK policy must register.
✅ Trade associations
If a trade association is acting on the direction of a foreign government to advocate a policy change, it must register, even if working through its membership.
✅ Lobbying contract
A UK lobbying agency is hired by a foreign government to influence ministers to reverse a policy. The agency must register under the political influence tier.
✅ Hotel contract with a Russian embassy
A London hotel hosts an event for the Russian embassy to promote investment. Because Russia is designated under the enhanced tier, the hotel must register within 10 days.
✅ Pharma research with Iran
A UK pharmaceutical company signs an agreement with an Iranian regulator to carry out research in the UK. As Iran is in the enhanced tier, registration is mandatory.
How to register with FIRS
The government is launching an online FIRS portal. Registrations must include:
- the nature and purpose of the arrangement
- details of the parties involved
- start and end dates
- the type and frequency of activities
- information about any expected outcomes
For existing agreements that will continue beyond 1 July 2025, there is a transition period until 1 October 2025 to register. For new agreements after 1 July, you must register within 28 days (political influence tier) or within 10 days (enhanced tier).
Changes to an arrangement (e.g., a new subcontractor or new activities) must be updated in the register within 14 days.
The public will have access to parts of the register, though certain details such as personal addresses or highly sensitive information will remain confidential if there is a safety risk.
Exemptions and commercially sensitive information
FIRS is not intended to be a catch-all. There are key exemptions, including:
- activities under UK government contracts
- recognised news publishers
- legal services provided by qualified lawyers
- diplomats and their families
- staff providing essential services to diplomatic missions
- purely academic collaborations unless there is a direction from a specified power
Notably, charities are not automatically exempt. If a charity is funded by, say, a foreign ministry with conditions on how the money is used for political campaigning, registration is required.
What about commercially sensitive information?
One practical business concern is the publication of commercially sensitive information. FIRS requires most political influence tier registrations to be published on a public register, and some enhanced tier registrations too.
However, you can request exceptions if publication would:
- prejudice your commercial interests
- reveal trade secrets
- impact tender bids
- reveal pricing, formulas, or confidential intellectual property
If this is case, evidence will be required — for example:
- non-disclosure agreements
- patent documents
- assessments of commercial harm
Reputational damage alone is not enough.
Enforcement and compliance risks
The Home Office will manage FIRS through a dedicated scheme management unit with powers to investigate, issue information notices, and refer matters to law enforcement.
Failure to register, providing misleading information, or carrying out unregistered activities under a qualifying arrangement are all criminal offences.
Penalties include:
- Up to 2 years’ imprisonment for offences under the political influence tier
- Up to 5 years’ imprisonment for offences under the enhanced tier
- Significant fines in either case
There is no approval requirement under FIRS, meaning activities can continue once registered.
Compliance steps for businesses
Given the complex interplay of FIRS and sector-specific scenarios, businesses should:
✅ Map all contracts and partnerships involving foreign governments, embassies, or state-controlled entities
✅ Review joint venture structures
✅ Examine whether any “directions” exist in these relationships
✅ Train staff to identify foreign direction
✅ Nominate a compliance officer to manage FIRS registrations
✅ Use the three-month transition window (ending 1 October 2025) to register any ongoing arrangements
