Foreign Influence Registration Scheme (FIRS)

FIRS is a two-tiered scheme designed to monitor foreign influence. The tiers are as follows:

• Political Influence Tier: requires registration of arrangements between a UK party and a foreign power to carry out political influence activities in the UK at the direction of said foreign power (please find the government guidance (Read the government guidance on the Political Influence tier).
• Enhanced Tier: requires registration of a broader range of activities for specified countries, parts of countries or foreign government-controlled entities where the government sees a threat to the safety of interests of the UK (Read the government guidance on the Enhanced tier).

The responsibility for registration can fall on the University where it is the University that makes an arrangement with a foreign power.

Where an arrangement is made by an individual researcher, academic or student the legal responsibility to register lies with that individual. Student societies are responsible for registering their own activities if relevant. 

Noncompliance is a criminal offence and may result in fines or imprisonment.

Activities within a university setting involving or supported by foreign governments may fall within scope of FIRS, particularly if they involve direct or indirect efforts to influence the UK government.

Key scenarios include:

• Research Collaborations:
  If collaborations involving foreign governments include advocating policy changes or engaging UK officials, they may require registration.
• Foreign Funding:
  Research funded by foreign governments that influences UK politics could trigger registration requirements.
• Public Engagement:
  Articles, talks or events directed by foreign powers aimed at influencing UK public opinion or policies may need to be registered (note that published research papers do not need to be registered if the direction by foreign powers is declared in the paper).

Anyone who believes that their work may be relevant to FIRS or if you have any questions related to the Scheme, please contact FIRS@admin.cam.ac.uk.

Arrangement: An arrangement is any type of agreement, whether formal or informal, to carry out activities in the UK. An arrangement can include contracts, MoUs, an order (or similar) of a good or service to be followed up with a bill or invoice, an informal quid pro-quo agreement.

Direction: A “direction” is an order or instruction to act to which a person is obliged or compelled, whether formally or informally, to comply. This could also take the form of a request, if there is a power relationship between the person and the foreign power which adds an element of control or expectation, for example through a contract, payment, coercion or the promise of future compensation or favourable treatment.

Foreign Power: A foreign power is defined as any of the following:

1. the sovereign or other head of a foreign State;
2. a foreign government, or part of a foreign government (for example, a ministry or department of a foreign government);
3. an agency or authority of a foreign government, or of part of a foreign government,
4. an authority responsible for administering the affairs of an area within a foreign country or territory (for example, a local government authority in a foreign country);
5. a political party which is a governing political party of a foreign government.

Entities that are owned or controlled by a foreign power, e.g. state-owned universities, labs or research institutes are not by default considered to be part of a foreign state.

Please note, within the context of this Scheme, the Republic of Ireland is exempt.

Political Influence Activities: To meet the definition of a ‘political influence activity’ an activity must meet both of the following criteria:

1. The activity must be carried out in the UK and be one of the following:

• A communication (e.g. emails, letters or meetings) to a senior public official or politician.
• A publication, except where it is reasonably clear that it is made at the direction of a foreign power.
• The provision of money, goods or services to an individual or entity in the UK (for example, providing consultancy services to a UK business).

2. The purpose, or one of the purposes of the activity must be to influence one of the following:

• An election or referendum in the UK;
• A decision of a Minister or Government department (including a Minister or Government department of Wales, Scotland or Northern Ireland);
• The proceedings of a UK registered political party (such as their manifesto commitments);
• A Member of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament or Senedd Cymru (when acting in their capacity as such).

The Political Influence Tier applies to arrangements to carry out political influence activities in the UK at the direction of any foreign power, with the exception of the Republic of Ireland.

There is a requirement to register with the scheme under the political influence tier if all of these four conditions are met:

1. A person makes an arrangement (whether formal or informal) with a “foreign power”.
2. The arrangement involves a “direction” from the foreign power.
3. The direction is to carry out “political influence activities” in the UK (whether by the registrant, or with or through someone else).
4. That no exemptions apply to the arrangement or activities.

The registration needs to be made within 28 days of entering the arrangement and will be published.

Political Influence Tier: Examples

• A research project that has been directed by a foreign power and involves political influence activities (e.g. proposing policy changes in the UK).
• A foreign power directs a UK researcher to write a policy brief that is presented to UK ministers or civil servants.
• A foreign power directs a researcher to produce a publication encouraging a particular political decision and this is not declared in the publication.
• A foreign power directs the running of a workshop encouraging take up of a particular technology and members of a political party are invited.
• A foreign power directs a student society to campaign against a UK government decision. The student society arranges a protest and seeks to influence their local MP. 

Key Points

• If there is no direction there is no registration requirement.
• If there are no political influence activities there is no registration requirement.

Anyone who believes that their work may be relevant to FIRS or if you have any questions related to the Scheme, please contact FIRS@admin.cam.ac.uk.

Enhanced Tier

Under the Enhanced Tier government may specify specific foreign powers or entities (please see below for currently specified powers and entities and find the government guidance here). Registration will be required for arrangements to carry out ‘relevant activities’ at the direction of these specified powers and entities.

‘Relevant activities’ are, by default, all activities in the UK and activities which take place abroad, but have effect in the UK (e.g. an email or social media post sent or posted by an individual overseas but targeted at individual in the UK). In some cases the Secretary of State may limit what constitutes ‘relevant activities’ for a specific power or entity.  

There is a requirement to register with the scheme under the enhanced tier if these four conditions are met:

1. A person makes an arrangement (whether formal or informal) with a specified foreign power or entity.
2. That arrangement involves a “direction” from the specified foreign power or entity.
3. The direction is to carry out “relevant activities” in the UK (whether by the registrant themself, or with or through someone else).
4. That no exemptions apply to the arrangement or activities.

The registration needs to be made within 10 days of entering the arrangement.

Specified Powers or Entities under the Enhanced Tier

The foreign powers and organisations currently specified under the enhanced tier are from Russia and Iran.

• Iran
  • Supreme Leader
  • Government of Iran and all its agencies and authorities (including all ministers and ministries and the armed forces and police).
  • Islamic Consultative Assembly of Iran
  • Judiciary of Iran.
• Russia
  • President
  • Government and all its agencies and authorities (including all ministers and ministries and the armed forces and police).
  • Federal Assembly and State Duma
  • Judiciary
  • United Russia Party, Communist Party of Russia, Liberal Democratic Party of Russia, Just Russia Party.

Enhanced Tier: Examples

• A specified foreign power directs a UK researcher to send research information to them or another entity.
• Specified foreign power funds a UK research project on a specific topic.
• A University hosts a cultural or language centre whose activities are directed by a specified foreign entity.
• A researcher organises a workshop at the direction of a specified foreign entity.
• A university receives a donation from a specified power directed for use to support students from the country.

Anyone who believes that their work may be relevant to FIRS or if you have any questions related to the Scheme, please contact FIRS@admin.cam.ac.uk.

Government involvement

• Neither tier of FIRS applies to arrangements involving the UK government or any arrangements involving an individual acting on behalf of the Crown or who holds Crown status. This does not include public bodies without crown status (e.g. UKRI, Research England or the Research Councils).
• The Enhanced Tier does not apply when any UK public body (including UKRI) is party to the arrangement (although this excludes local government, schools and other universities). This includes projects partially funded by UKRI and a specified foreign power.

Public communications

• Public communications (e.g. research papers) do not need to register under the political influence tier if it is clear that the activity has been made at the direction of a foreign power.

Postgraduate research funding

• Students receiving financial support from a foreign state will not ordinarily have to register their funding arrangement under the enhanced tier provided activities are limited to those necessary to complete the course, acknowledge the funding and comply with expected standards of conduct (e.g. providing the funder with personal details or progress updates. If ATAS is needed, the exemption only applies if ATAS clearance has been obtained.
• Where a university is in an arrangement with a foreign power to facilitate an arrangement describe above, that institution is also exempt from registering under the enhanced tier.

Visitors and Travel

• Visitors from or travel to specified countries is not covered.
• Visitors are required to register if they have been directed by the specified foreign power or entity to carry out relevant activities in the UK.

If you have any questions, please contact FIRS@admin.cam.ac.uk.

Registration needs to be undertaken by whomever makes the registerable arrangement (individual or university).

If you believe that you have a registrable arrangement that needs to be registered by the University please contact FIRS@admin.cam.ac.uk for support.

If you are unsure whether your arrangement has already been registered by the University, please contact the email above (individuals are legally responsible for making sure that registration has occurred before enacting registrable arrangements).

Please note: the University is not responsible for subsidiaries or student societies. 

Material Changes

The arrangement will be placed on a public register. Registrants will be required to update their registration within 14 days when there is a material change to the arrangement and to comply with information notices from Government. 

The following constitute a material change:

• A change in the end date of the activities (for example, where a project which is registerable gets extended),
• New researchers or academics becoming involved in registerable activities, where they are external to the organisation which has registered,
• New activities to be carried out under an existing arrangement, where those activities are also registerable under FIRS.

Anyone who has a registered arrangement and believes that a material change is going to occur or has occurred should  contact FIRS@admin.cam.ac.uk.