New legal requirement: Foreign Influence Registration Scheme (FIRS)

From 1 July 2025, a new UK law, the Foreign Influence Registration Scheme (FIRS), comes into effect. It’s designed to improve transparency around foreign influence in UK political life.

This means that some UCL staff and students may need to register certain activities with the UK Government, and that UCL also has a requirement as an institution to register some activities.  

What is FIRS? 

FIRS is part of the National Security Act 2023. It requires individuals and organisations to register political influence or other specified activities carried out in the UK at the direction of a foreign power, including foreign governments, state-controlled organisations, or entities acting on their behalf. 

There are two tiers: 

Political Influence Tier:
  • Activities aimed at influencing UK politics (e.g. government decisions, elections, political parties) at the direction of a foreign power.
  • Activity must be registered within 28 days of an arrangement being made.
  • The maximum penalty for failure to comply is two years imprisonment.  


    • Enhanced Tier:
  • Broader activities (e.g. research, events, consultancy) directed by specified foreign powers.
  • The foreign powers currently specified are located in Russia and Iran. Activity must be registered within 10 days of an arrangement being made.
  • The maximum penalty for failure to comply is five years imprisonment.    

    • What does this mean for UCL staff and students? 

    If you are carrying out activities in the UK at the direction of any foreign organisation or individual, you should read the UK Government guidance on FIRS for research and academia and consider whether the activity should be registered under the scheme.  

    UCL will manage registrations for institutional activities, whereas staff and students may need to register their own activities if these are not arranged by UCL.  

    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. There is also guidance about the distinction between institutional-level and individual activity on the FIRS Research Compliance and Assurance webpage , but if in any doubt about whether you need to register individual activity yourself then always contact UCL’s compliance team at ris.complianceandassurance@ucl.ac.uk. 

    There are strict deadlines for registration, and penalties for non-compliance. The law comes into effect from 1 July 2025, but organisations and individuals have up to three months to register existing activity. After this, new activity should be registered on an ongoing basis.  

    What activity needs to be registered? 

    Activity may need to be registered if it is: 
  • Collaborating with a foreign government or state-linked organisation on research or public engagement. 
  • Publishing or presenting work that could influence UK political decisions, at the request of a foreign entity. 
  • Hosting or attending events in the UK that are directed by a foreign power and aim to influence UK policy. 


    • It is important to note that not all’international activity is in scope. Registration is only required if the activity is directed by a foreign power and meets the criteria. 

    Registration does not mean that an activity is unwanted or illegitimate. Providing activities are registered, they may go ahead without restriction. 

    Examples of typical scenarios for a university and whether they are in scope

    Section 4 of the UK Government’s FIRS guidance lists example scenarios typical for a university that may require registration. Examples include: 

    You’re asked by a foreign embassy to produce a research report that will be used to influence a UK parliamentary debate 
  • Registration required, as this is political influence directed by a foreign power


    • A foreign state-owned think tank asks you to speak at a UK event to promote a policy change
  • Registration required, as if the aim is to influence UK policy and it’s at their request, it’s in scope


    • You write an article supporting a UK policy change, and it’s commissioned or paid for by a foreign government 
  • Registration required, as this is public communication with political intent, directed by a foreign power 


    • You co-author a paper with a university in a specified country (e.g. Russia), but there’s no instruction to influence UK politics 
  • No registration needed, as unless there’s direction to influence UK political matters 



    • You attend a UK conference funded by a foreign government, but you’re not asked to promote any political message 
  • No registration needed, as attending alone doesn’t trigger registration


    • You receive a research grant from a foreign funder, but there’s no expectation to influence UK policy 
  • No registration needed, as funding alone doesn’t count as "direction"

    • How we will support you  

    UCL will manage registrations for all’institutional activities. 

    We’ll be regularly updating the information and FAQs on FIRS on UCL’s Research Compliance and Assurance webpages to help support you further.  

    Over the coming three months we will be engaging further with specific teams and offices to support them throughout the registration process. This will include visiting different committees and groups to share information about the process and their responsibilities, running training and support sessions with different staff groups, and sharing templates and tools to support information sharing.

    If you would like to request an additional session to support your teams or to find out more information about the engagement planned, please.
  • University College London, Gower Street, London, WC1E 6BT (0) 20 7679 2000