Under provisions in the National Security Act 2023 expected to come into force later in 2024, individuals and organisations will be required to register certain arrangements involving foreign powers. Most arrangements on the register will be open to public inspection. The obligation applies to both new and existing arrangements. These measures form part of a move to update UK legislation around foreign power influence, alongside measures such as the National Security & Investment Act 2021 and the 2023 Act’s foreign interference offences which came into force on 20 December.
Our briefing outlines the scope of the scheme and the Government’s draft guidance.
The Government considers that the sectors most likely to be affected by the scheme include:
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Political lobbying/consultant lobbyists;
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Management consultancy, advertising and public relations;
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Representative associations;
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"Cultural institutions";
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Non-government organisations;
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Charities;
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Legal sector (where not covered by the exemption for legal services);
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Media (where not covered by the exemption for domestic or international news publishers);
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"Other businesses and sectors" such as defence.
The Government intends that sector-specific guidance will be published ahead of the FIRS scheme going live. This guidance is to be developed through consultation panels. It also remains to be seen whether the Government will exempt additional categories of arrangement from the scheme; the position may become clearer when any sector guidance is published.