Understanding the UK's Foreign Influence Registration Scheme (FIRS): what it means for charities and NGOs

On 1 July 2025, the UK Government introduced the Foreign Influence Registration Scheme (FIRS), marking a significant shift in how foreign influence is tracked and disclosed within the UK. The legislation is intended to improve national security by increasing transparency around arrangements between foreign governments and UK entities, particularly where those arrangements involve activities that could influence UK political decisions.

In this blog, we break down what the FIRS is, what it requires, and what you should do if your organisation is working with a foreign government, particularly if your activities could be seen as politically influential in the UK.

What is the Foreign Influence Registration Scheme?

FIRS is a mandatory registration scheme designed to monitor arrangements between UK-based entities and foreign powers that involve political influence activities in the UK. The Government describes the scheme as a way to gain “unprecedented insight into covert attempts by overseas powers to influence UK democratic processes.”

The legislation applies broadly to individuals and organisations (including charities) that are directed by a foreign government to carry out such activities. The aim is to prevent covert foreign interference while enhancing the UK's ability to understand and respond to foreign influence.

What needs to be registered?

You need to register under the political influence tier if:

• you are directed by a foreign power (such as a government or government department); and
• you carry out, or arrange for others to carry out, political influence activities in the UK.

The enhanced tier is only relevant to organisations working with Russian or Iranian entities and is not the focus of this blog.

What counts as political influence activity?

According to the guidance, political influence activities include:

• communications intended to influence UK elections or referendums;
• attempts to influence the decisions of UK government ministers or departments (including devolved administrations);
• activities targeting UK political parties or parliamentary proceedings;
• meetings with MPs, peers, or other political figures with a view to shaping policy.

An example from the guidance is a meeting with a senior civil servant to influence the UK Government’s response to overseas disasters is considered a political influence activity.

Direction vs. independence: when is registration not required?

A key consideration is whether the UK organisation is being directed by the foreign power or simply acting independently with funding support.

Registration is not required if:

• the foreign funding is unrestricted or does not stipulate specific politically influential activities in the UK;
• the political influence initiative originates from the UK organisation, not the foreign government.

Some examples from the official guidance of scenarios that do not require registration are as follows:

1. An NGO receives general funding from a foreign ministry and uses it to host a UK event aimed at changing laws. Since the government didn’t direct this, registration is not needed.
2. A UK charity applies for a grant from a foreign ministry, proposing its own political advocacy agenda. The ministry approves the plan but doesn’t influence the method or goals. Again, this does not require registration.

Contrast this with cases where the foreign government sets the agenda or activities – these would generally need to be registered.

A case study: is your charity's arrangement registerable?

Let’s say a charity receives a contract from a foreign government to strengthen climate and conservation initiatives through collaborative events and policy-oriented research. The project aims to include conversations with UK government officials and other stakeholders to inform environmental policy.

While the contract doesn’t explicitly say “influence UK government policy,” its aims and structure strongly suggest political influence. If the foreign government shaped the activities or outcomes expected, that could count as direction – making registration mandatory.

However, if the charity initiated the activity independently and merely secured funding to support its own pre-defined plans, that may not require registration.

The fine line between being “funded by” and being “directed by” is crucial – and potentially the difference between legal compliance and criminal liability.

The registration deadline and legal consequences

The 28-day rule is clear: registration must occur within 28 calendar days of the arrangement being made. For example, an agreement signed on 4 August would need to have been registered by 31 August.

Failure to register a qualifying arrangement is a criminal offence, carrying penalties of up to two years’ imprisonment.

Key points:

• Activities can begin within the 28-day window, even if registration hasn’t yet been completed.
• Registration is deemed complete once the form is submitted (you don’t have to wait for confirmation).
• It is the organisation, not individual employees, that bears the legal responsibility.

How to register

The registration process is straightforward and must be completed online. You'll need to:

• create a FIRS account;
• complete the political influence tier form; and
• provide full details of the foreign government arrangement.

You can find full guidance here: How to register online

There’s also a registration checker on the site – but it requires logging in, so external advisors cannot use it on your behalf.

Final thoughts

While the goal of FIRS is understandable – protecting the UK’s democratic integrity – the law's broad scope and reliance on self-assessment may place an undue burden on innocent organisations, particularly charities and NGOs engaged in legitimate, open collaboration with foreign governments.

If there’s any doubt about whether your activity counts as political influence and whether it’s being directed by a foreign power, the safest course of action is to register. The penalties for getting it wrong are serious.

For organisations navigating this new regime, legal advice and a thorough review of contracts and grant terms are essential.

If you’re unsure, please get in touch with Tom Murdoch or via our enquiry form.