FIRS is intended to improve the understanding and transparency of activities taking place in the UK that are at the instruction of, or “directed” by, a foreign power or foreign state-controlled entity.

The legislation requires UK-based individuals and organisations to register arrangements and activities which are designed to influence the political and public life in the UK or are directed by foreign powers or foreign power-controlled entities specified in the legislation.

What is covered by FIRS?

Arrangements are organised into two tiers:

• The Political Influence Tier – where an individual or entity is instructed by any foreign power to influence UK political and public life; and
• The Enhanced Tier – where an individual or entity is instructed by a foreign power that has been specified in the legislation.

Where arrangements, whether formal or informal (a written contract is not necessary for it to be captured by FIRS), fall within the scope of one of these tiers, it must be registered on the government portal within 10 calendar days. Failure to comply with FIRS carries criminal penalties, including fines and imprisonment.

It is important to note that important exemptions applying to higher education have been agreed through consultation with the Home Office. These exceptions are designed to focus the legislation on common arrangements and activities in the HE sector, which are specifically directed by foreign powers. The requirement to register is not an implication of wrongdoing.

What countries are covered by FIRS?

When FIRS comes into effect, only Iran and the Russian Federation have been specified under the Enhanced Tier. All arrangements with the government and government-controlled entities in Iran and Russia are captured by the legislation and require registration.

What do I need to think about?

• Political Influence Tier – are you undertaking any activities on behalf of a foreign power that seek to influence changes in UK political and public life? For example, influencing public policy, legislation or regulation; lobbying MPs, committees or Parliamentary groups (eg a Select Committee, All Party Parliamentary Group etc.). If so, you ought to consider whether your activity is captured by FIRS.
• Enhanced Tier – if you are undertaking any activities with individuals or entities based in Iran or Russia, you are strongly encouraged to contact research@mailbox.lboro.ac.uk at your earliest opportunity to discuss the activity with the Trusted Research and Innovation team.

Where can I learn more about FIRS?

A dedicated FIRS page has been created as part of the Safer Partnerships and Trusted Research campaign site. Additional guidance, including specific guidance for the academic sector, can be found on the Home Office website.

All enquiries should be directed to trusted.research@mailbox.lboro.ac.uk