The Foreign Influence Registration Scheme will go live from 1st July 2025
Key contacts
The government has announced that the Foreign Influence Registration Scheme will go live from 1st July this year.
The Scheme requires the registration of:
- Arrangements to undertake political influence activities in the UK that are directed by a foreign power (the “Political Influence Tier”); and
- Arrangements with foreign entities for such activities as may be specified (the “Enhanced Tier”).
Arrangements registered under the Political Influence Tier will, subject to some exceptions, be published on a publicly available register.
A key intent behind the Scheme is to increase transparency over the influence that foreign powers seek to wield over UK politics. The Scheme does not prohibit any activities but requires their registration with an aim to transparency.
The Political Influence Tier
Arrangements are only required to be registered under the political influence tier where there is a “direction” from a foreign power to undertake political influence activities. A “direction” is an order or instruction to act which may be explicit or implicit in the context of inequal power dynamics.
There are several exemptions to registration including for recognised news publishers, legal activities carried out by lawyers, diplomats and their family members, and arrangements to which the UK itself is a party.
Political influence activities include:
- communications to government decision makers (including not only elected officials, but also election candidates, and senior civil servants);
- communications to the public intended to influence political opinion where the source of the influence is not made clear; and
- providing funds, goods, or services to UK persons for a political purpose.
The activity must be for the purpose of influencing UK public life.
The Enhanced Tier
The Enhanced Tier will evolve over time as the government specifies relevant foreign powers and foreign entities.
The government has announced intentions for elements of the Iranian and Russian state to be specified under the Enhanced Tier without limiting the scope of relevant activities. This means that any person – whether an individual or an entity – carrying out activity as part of any arrangements with those specified Iranian or Russian entities will have to register them under the Scheme.
Practical Implications
Registration under the Scheme will be via a government portal using information laid down in regulations. Organisations should begin the process of internal information gathering and developing procedures to ensure continuing compliance.