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New UK rules require registration of foreign-influenced political or sensitive activities. All UCL staff and students should check if their work falls under the Foreign Influence Registration Scheme.
Part of the UK’s National Security Act 2023, the Foreign Influence Registration Scheme (FIRS) aims to enhance transparency around foreign influence in UK politics. From 1 July 2025, individuals and organisations will be required to register arrangements with foreign powers when engaging in political influence or other specified activities in the UK. A 3-month grace period is provided for registering existing arrangements.
FIRS is distinct from the National Security and Investment Act 2021 as it focuses on registering specific activities or arrangements to help safeguard UK institutions from covert foreign influence. It does not require activities or arrangements to be approved before they can take place.
The scheme applies to all UCL staff and students. Use the guidance below to determine whether your activities require registration, are exempt, or fall outside the scheme. Registration does not imply approval of the activity.
Scheme structure
FIRS consists of 2 tiers to monitor foreign influence:
Political Influence tier
Registration is required if you are directed by a foreign power (excluding the Republic of Ireland) to engage in activities intended to influence:
- UK elections or referendums
- Decisions by Ministers or government departments (e.g. select committee appearances, policy proposals)
- The activities of UK-registered political parties (e.g. influencing manifesto policy commitments)
- Members of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament, or Senedd Cymru (e.g. publishing articles supporting legislation).
“Direction” refers to an instruction or request from a foreign power that carries an element of control or expectation, such as through payment, coercion, or contractual obligation. Funding, collaboration, or shared views do not meet the threshold, and foreign ownership does not automatically imply direction.
Arrangements need to be registered within 28 calendar days of being made, and activities may proceed during this period. Registrations need to be updated within 10 calendar days if there is a change to the arrangement.
Some information will be published on an online public register to achieve the transparency aims of the scheme, with personal and sensitive details withheld. Information will not be published if it risks national security, individual safety, or discloses commercially sensitive data..
Enhanced tier
Applies to arrangements involving specified foreign powers or foreign power-controlled entities (FPCEs) considered a potential risk to UK interests. This includes:
- Individuals or organisations directed by a specified foreign power or FPCE
- FPCEs conducting relevant activities themselves.
Direction may be formal (e.g., a contract) or informal (e.g., in kind, benefit, or coercion). Relevant activities include (but are not limited to):
- Commercial activities
- Provision of goods and services
- Research activities
- Attendance at conferences or events.
Arrangements need to be registered within 10 calendar days of being made, and activities cannot commence until registration is complete. Material changes need to be registered within 14 calendar days.
Registrations under this tier are not published unless some activities overlap with the political influence tier.
Exemptions
Exemptions from enhanced tier registration apply in specific cases, such as studentships or arrangements involving UK public bodies (including UKRI). This includes:
- Arrangements with UK Crown Bodies
- Foreign governments (not required to register)
- Diplomatic staff and their families
- Legal professionals conducting legal work
- Diplomatic functions
- Certain funded education arrangements
- Government administrative and technical services.
UCL activities potentially in scope
Some UCL activities involving support or collaboration may fall under FIRS, particularly if they aim to influence UK government decisions. Examples include:
- Research and funding: Collaborations involving foreign entities, including funders, that engage UK officials
- Public engagement: Events, publications or any other type of public engagement taking place at UCL intended to shape UK public policy, opinions, or political views.
Academic collaboration only requires registration if it involves political influence directed by a specified foreign power or entity. Registration does not mean approval is required before academic and research collaborations can take place, unless other regulations, such as Export Controls, apply.
Further examples of registerable and non-registerable arrangements relevant to academia are available on the GOV.UK website.
How to register activities
For now, designated UCL staff will manage registrations for organisational-level activities through existing approval processes. Staff and students can contact our Compliance and Assurance team at ris.complianceandassurance@ucl.ac.uk with any queries on FIRS.
Further details on UCL’s long-term registration process will be published once available. Staff and students carrying out registerable activities outside their job role and organisational arrangements will need to register individually and should refer to the GOV.UK website for more information.
Information required for registration
- Description of the activity (nature, purpose, intended outcomes)
- Start and end dates
- Frequency of the activity
- Individuals or entities involved
- Details of the directing foreign power or entity.
Enforcement
A Scheme Management Unit within the Home Office will oversee FIRS, with powers to issue information notices and investigate non-compliance. Failure to register when required is a criminal offence and may result in fines or imprisonment.