The Foreign Influence Registration Scheme applies to all staff and students and is not limited to research or research-related activities. Additionally, spin out companies, visitors to the university and student societies may have obligations to register.

Please review the guidance carefully to ascertain if your specific scenario, arrangement, or activity requires registration, is exempted, or does not otherwise require registration. This is a registration process only and there is no approval of any registered activities required or implied in the registration process.

FIRS registration requirements are split into two tiers:

• the political influence tier, which requires registration of arrangements with any foreign power (except the Republic of Ireland) to carry out or arrange for others to carry out, political influence activities in the UK. Note, there are some exemptions to publication which may be requested as part of the registration process.

• the enhanced tier, which requires the registration of arrangements to conduct a wider set of activities but only with specified foreign powers or specified foreign power-controlled entities. At the current time (July 2025), this applies to arrangements with the States of Russia and Iran, and certain entities in those countries.

Registration is required by the individual or organisation who makes the arrangement (in scope of either tier) with the foreign power, specified foreign power or foreign power-controlled entity. It is the arrangement that must be registered, not each individual activity that will be carried out. Therefore, where other individuals or organisations are involved in carrying out the registerable activities, they should check that the arrangement is registered prior to carrying out the activities.

Political influence activities include certain communication activities, public communication activities or the provision of money, goods, or services, where they are intended to influence any 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).

Political influence activities in the research, academia and higher education sector could include:

• Communications with senior civil servants and ministers in a government department which seek to influence education policy.
• Appearance at select committees and other parliamentary activities which provide information seeking to influence MPs or peers.
• The publication of an article which encourages support for a Private Member’s Bill, without stating that the publication was directed by a foreign power.
• The presentation of research outcomes and associated policy proposals to senior civil servants.

Arrangements under the political influence tier must be registered within 28 calendar days of the arrangement being made. Activities may take place within that 28-day window without prior registration.

The maximum penalty for failure to comply with the requirements of the political influence tier is 2 years imprisonment.

Further information:

• Common scenarios under the political tier can be found in the guidance and include:
• Research projects for (or in collaboration with) foreign powers.
• Policy workshops and conferences.
• Student political campaigning activities.

Guidance on the political tier:

https://www.gov.uk/government/publications/foreign-influence-registration-scheme-political-influence-tier/guidance-on-the-foreign-influence-registration-scheme-political-influence-tier-accessible-version

Individuals and organisations are required to register arrangements under the enhanced tier if the arrangement involves a direction from the specified foreign power or entity to carry out, or arrange for others to carry out, a broader range of “relevant activities” in the UK. Specified foreign power-controlled entities are also required to register any “relevant activities” that they carry out themselves in the UK.

At the current time (July 2025), this applies to arrangements with the States of Russia and Iran, and certain entities in those countries. Registration requirements only apply where there is a “direction” from the specified foreign power, or specified foreign power-controlled entity, to act. Separate guidance has been produced setting out the foreign powers and foreign power-controlled entities specified under the enhanced tier.

“Relevant activities” in the context of academia could include:

• Hosting an event or conference in the UK at the direction of a specified foreign power or specified foreign power-controlled entity.
• Undertaking a research project directed by a specified foreign power or specified foreign power-controlled entity.
• Sending information from the UK to a specified foreign power or specified foreign power-controlled entity.

Registration of arrangements under the enhanced tier is required within 10 calendar days of the arrangement being made, and before activities are carried out. It is an offence to carry out relevant activities under a registerable arrangement without the arrangement being registered first. The maximum penalty for failure to comply with the requirements of the enhanced tier is 5 years imprisonment.

Further information:

Common scenarios under the political tier can be found in the guidance and include:

• Research grants, university-level consultancy and other funding arrangements.
• Philanthropic donations.
• Academic visitors and students from countries whose government has been specified.
• Partnerships with state-controlled universities.

Guidance on the enhanced tier:

https://www.gov.uk/government/publications/foreign-influence-registration-scheme-enhanced-tier/guidance-on-the-foreign-influence-registration-scheme-enhanced-tier-accessible-version

There are exemptions (covered in detail in the guidance), which include scholarship funding and where UK public bodies (such as the NHS or UKRI) are party to the agreement or arrangement. Activity is also only registerable when carried out in the UK; any activities carried out wholly at overseas universities (as may be the case with some research collaborations or transnational education arrangements) would not require registration. Careful review of the guidance for the relevant tier is needed to confirm whether the activity is covered under the exceptions or whether registration is required.

Exemptions from registration apply to:

• UK crown body arrangements (both tiers).
• Foreign powers acting overtly (both tiers).
• Diplomatic family members (both tiers).
• Legal activities carried out by a lawyer (both tiers).
• Recognised news publishers (political influence tier only).
• Sovereign wealth funds carrying out investment-related activities (political influence tier only).
• Activities that are reasonably necessary to support diplomatic missions (enhanced tier only).
• UK public body arrangements (enhanced tier only).
• Certain funded education arrangements (enhanced tier only).
• Certain government administrative services (enhanced tier only).

Exemptions most likely to be relevant to the academia, higher education and research sectors include:

• UK Crown Body Arrangements (both tiers)
• UK public bodies arrangements (enhanced tier only)
• Funded education arrangements (enhanced tier only)

There are detailed conditions around the exemptions and further information on the applicability of exemptions along with example scenarios are provided in the Sector Specific Guidance on the Foreign Influence Registration Scheme (FIRS): Academia and Research Sector

In addition, further detail on all of the exemptions can be found in the guidance on the political influence tier or guidance on the enhanced tier.

• Arrangement: Any type of agreement, whether formal or informal. This could include a contract, memorandum of understanding (MOU) or quid pro-quo informal agreement or arrangement. Further detail is in Political Tier chapter 3 condition 1 and Enhanced Tier chapter 3 condition 1.

• Foreign Power": The scheme broadly defines a "foreign power" to include foreign governments, heads of state, government agencies, and governing political parties. It also encompasses individuals acting in an official capacity on behalf of such entities. Notably, intergovernmental organisations (e.g., EU, ASEAN) and certain territories (e.g., the Republic of Ireland) are excluded.

• Specified foreign power: A foreign power which has been specified through regulations under the enhanced tier of FIRS. Currently (July 2025) the States of Russia and Iran.

• Direction: An order or instruction to act to which a person (or organisation) is obliged or compelled, whether formally or informally, to comply. A “direction” from a foreign power (politic tier), a specified foreign power, or specified foreign power-controlled entity (enhanced tier) may be given formally (such as by means of a contract) or informally (such as through a quid-pro-quo arrangement).

Where the conditions for registration under either tier of FIRS are met, it is the individual or organisation which is in the arrangement with the foreign power (political influence tier) or specified foreign power or entity (enhanced tier) that is required to register.

Where the University has entered into a registerable arrangement: the registration will be made on behalf of the University by the FIRS contact (see contacts). Please notify the relevant contact via  res-comms@lancaster.ac.uk if you are aware of an arrangement that is registerable by the University.

The university will not be responsible for registration where:

• an individual member of staff or student has entered into a registerable arrangement in their own name (for example, private research or private consultancy work): the individual is responsible for registration.
• Where a spinout company formed by academics from the University has entered into a registerable arrangement: the spinout is required to register.
• Where a subsidiary company of the University has entered into a registerable arrangement: the subsidiary is required to register the arrangement.
• Where a student society has entered into a registerable arrangement: the society is required to register the arrangement.
  
  Whilst arrangements could be made by academics using their university email address, and activities may be carried out on a university campus, this does not in itself transfer responsibility for registration onto the university.
  
  Further details about the information required at registration, and information about the public register, including the specific arrangements which will be published, are available via the government’s guidance on registration and the public register.