Foreign Influence Registration Scheme: the higher education and research sector

Our latest update on the Foreign Influence Registration Scheme looks at some key aspects from the various sets of Government guidance, including sector specific guidance and what this means for higher education institutions’ compliance programmes.  The scheme is intended to provide greater transparency for foreign power influence on UK politics and Government and also to provide greater assurance in relation to the activities of specified foreign powers or foreign power-controlled entities.  FIRS is due to take effect from 1 July.

The scheme consists of two tiers:

• A political influence tier requiring registration of “arrangements” with “foreign powers” to carry out “political influence activities in the UK”.  
• An enhanced tier requiring registration of a much wider range of activities where the foreign power or foreign-power controlled entity involved has been specified in regulations.  Under the enhanced tier, the Government is currently expected to specify foreign powers / entities connected to Russia and Iran. 

The detailed definitions and requirements under each tier are considered further in our article.

FIRS requires organisations and individuals to register in scope arrangements where the specific conditions in either tier of the FIRS scheme are met.  

Whilst the requirements under each tier are complex and will only bite where the relevant definitions are met, reviewing compliance in practice is important as there are various potential criminal offences for organisations and individuals where there is a failure to comply with the legislation.  

Our article outlines further detail on the scope and working of the scheme including matters such as registration and exemptions, as well as outlining a range of compliance and awareness-raising aspects (both for staff and, where appropriate, students).  

For in-scope arrangements that are “live” on 1 July there is a three month grace period (under both tiers) requiring registration before 1 October 2025.  For in-scope arrangements made on or after 1 July, FIRS requires:

• Registering within 28 days arrangements that fall within the political influence tier;
• Registering within 10 days arrangements that fall within the enhanced tier (and under this tier, arrangements must be registered before relevant activities are carried out).

Certain information about political influence activity (under either tier) will usually appear on a public register, subject to certain exceptions that can be claimed if supported by evidence.

Please contact the authors or your usual Mills & Reeve contact if your institution needs assistance in relation to the FIRS regime or other compliance matters.