FIRS things first – Staying compliant with new Foreign Influence Rules

What is FIRS?

Transparency in research is more important than ever - and a new legal framework is here to support it. The Foreign Influence Registration Scheme (FIRS), introduced under Part 4 of the National Security Act 2023, requires UK institutions and individuals to register certain arrangements made with foreign powers. Specifically, if you're involved in political influence activities in the UK at the direction of a foreign entity, registration is now a legal must.

Government guidance is available, as well as a sector specific guide for Academia and Research.

FIRS is designed to shine a light on foreign influence in UK politics, deter covert activity, and provide a tool to disrupt hostile threats. For universities, this means reviewing any agreements - whether institutional or individual - that could fall under the scheme.

FIRS operates across two tiers: the Political Influence Tier and the Enhanced Tier, each with its own criteria and obligations.

Political Influence Tier

Under the Political Influence Tier, individuals and organisations must register if they’re acting at the direction of a foreign power to carry out - or arrange for others to carry out - political activity in the UK.

In a higher education context, this could include things like:

• Hosting policy-focused workshops or conferences
• Publishing articles that support legislation (e.g. a Private Member’s Bill) without disclosing foreign direction
• Engaging in student political campaigning
• Conducting research projects around political activity for, or in collaboration with, foreign powers.

It’s important to note that registration is only required when there is explicit direction from a foreign power to engage in political influence. If a research project unintentionally leads to policy change, or if a researcher maintains full independence over their findings and clearly discloses any foreign affiliations, then registration may not be necessary.

Enhanced Tier

Some foreign relationships come with extra scrutiny. Under the Enhanced Tier, individuals and organisations must register if they are directed by a ‘specified’ foreign power or entity to carry out certain ‘relevant activities’ in the UK. This tier allows the government to monitor a broader range of activities involving countries identified as higher risk.

Currently, the ‘specified’ foreign powers under the enhanced tier are: Russia and Iran.

So, what counts as a relevant activity? These are specified by the Secretary of State and could include:

• Hosting an event or conference in the UK at the direction of a ‘specified’ foreign power
• Undertaking a research project with direct input from a ‘specified’ foreign power
• Sending information from the UK to a ‘specified’ foreign power

In the university context, this might involve:

• Research grants, consultancy, or funding arrangements with conditions attached
• Philanthropic donations from specified foreign sources
• Academic visitors or students from specified countries
• Partnerships with state-controlled universities.

If you receive conditional funding from a ‘specified’ foreign power, registration is required before the activity begins. However, unrestricted grants - where researchers retain full autonomy over how the funds are used - are not considered to be ‘under direction’ and typically do not require registration.

Exemptions

Not every arrangement needs to be registered under FIRS - for universities, the most relevant exemption is the ‘UK arrangement’ exemption. If your collaboration includes a UK government department, an entity with Crown status (like civil servants), or is partially funded by the UK government (such as through the International Science Partnerships Fund (ISPF)), then registration may not be required.

However, it’s important to note that this exemption does not apply to arrangements involving public bodies without Crown status, such as UKRI or Research England. So while some partnerships may fall outside the scope of FIRS, others could still trigger registration requirements - particularly if they involve direction from a foreign power.

How to register

If your activity falls under FIRS and is part of your role at the university, Research Services is here to work with you on the registration. We’ll work with you to submit the registration under the LBU profile and ensure your registration is accurate, fulfils the requirements and is submitted on time.

Keep in mind the deadlines:

• For the Political Influence Tier, registration must be completed within 28 calendar days.
• For the Enhanced Tier, registration must be completed within 10 calendar days - and activity cannot begin until registration is confirmed.

If you’re unsure whether your research is in scope, or just want to talk it through, please contact Research Services - Charlotte Pettitt, Research Integrity and Ethics Manager.

FIRS at LBU

To help staff understand FIRS and what it means for their work, we’ll be hosting information sessions throughout the autumn and early next year. These sessions will provide practical guidance, answer questions, and walk through real examples of how the scheme might apply in a research setting - so keep an eye out for more details soon.

In the meantime, we’re also conducting an audit of ongoing research projects to identify any activities that may fall within the scope of the scheme. This proactive approach will help ensure we’re fully compliant and ready to support researchers across the institution.