An interesting email I received on my Warwick mail, about the newly established Foreign Influence Registration Scheme in the UK. There is hardly any likelihood I could be concerned by a registration of my activities towards political influence, especially since State-owned universities, State-funded visiting grants, and domestic publishers are not covered by this registration.
On the 1 July 2025 the UK government’s Foreign Influence Registration Scheme (FIRS) came into force and university activities may be captured within this legislation and will therefore require registration. This email is to let you know how this might affect your departments, as well as what the University will be doing to manage compliance with the scheme.
FIRS was authorised under the National Security Act 2023 and sits under the remit of the Home Office. The scope of the legislation is to increase transparency about foreign political influences on activities in the UK. The scheme has two tiers, the political influence tier and the enhanced tier.
The two tiers both serve the same broad aims, but have slightly different requirements and parameters, including the time we have to register the activities. Organisations or individuals in UK will need to register any applicable activities with the Home Office via their online portal, and some of this information will be part of a public register.
Please note that whilst is this email has been sent by R&IS, the activities extend beyond research and cover all relevant university activities.
Political Influence Tier
Any activities where a foreign power directs an individual or an entity to conduct political influence activities i.e. a communication or action designed to influence an election, governmental or party-political decision, or the actions of an elected official. Registration of foreign influence arrangements under the political tier must be within 28 calendar days, activities may take place within the 28 day window without prior registration.
The maximum penalty for failure to comply is 2 years imprisonment.
Examples of political activities in HEI could include:
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- 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
Enhanced Tier
Any activities for any purpose which are directed by a specified list of entities dictated by the government. Presently, the specified entities are the governments and government departments of the Russian Federation and the Islamic Republic of Iran. Registration of foreign influence arrangements under the enhanced tier must be within 10 calendar days and before any activities are carried out.
Failure to register, or knowingly carrying out unregistered relevant activities, can lead to significant penalties, including imprisonment of up to 5 years and unlimited fine
State-owned companies and universities are not considered to be part of a foreign government in the eyes of this legislation.
It should be noted that requirement is to notify through registration and approval, and permission is not required, the activity can proceed provided the registration requirements have been met.
With respect to research, R&IS will be incorporating checks to ensure compliance with FIRS into our processes for supporting grants and contracts at the pre-award stage, and other professional services teams may do similar within their areas. We will need to provide some information to the Home Office as part of the registration, and where we identify a need to register, we will need to complete the registration before any contracts are signed or work commences.
We encourage departments and individual members of staff to be informed about the requirements created by FIRS and in this regard we have developed some guidance.
