What is the National Security Act 2023?
The National Security Act 2023 received Royal Assent on 11 July 2023, and parts 1 to 3 of the Act came into force on 20 December 2023. Part 4 of the Act which contains the Foreign Influence Registration Scheme (FIRS) is effective from 1 July 2025.
The Act introduces several measures designed to address potential threats to national security arising from a variety of sources, including espionage, sabotage and persons acting for foreign states. These measures include ensuring transparency of political influence activities carried out by or on behalf of foreign states, by a process of registration of such activities and connected arrangements within statutory timeframes on a public register managed by The Home Office.
Please Note: The following guidance principally concerns Imperial’s response to the Foreign Influence Registration Scheme (FIRS), implemented as secondary legislation under Part 4 of the National Security Act 2023.
Foreign Influence Registration Scheme (FIRS)
The Foreign Influence Registration Scheme (FIRS) is effective from 1 July 2025. FIRS is designed to protect the safety and interests of the UK by improving the understanding of activity taking place in the UK at the instruction of a foreign state or certain foreign state-controlled organisations.
FIRS comprises a political influence tier and an enhanced tier. The scheme requires individuals and organisations to register their arrangements with foreign powers and certain foreign power-controlled entities where they are directed to carry out certain activities in the UK. Further detail on the requirements of each tier of the scheme is provided below.
FIRS Tiers
The enhanced tier requires:
- individuals or organisations to register where they are directed by a specified foreign power or specified foreign power-controlled entity to carry out, or arrange for someone else to carry out, “relevant activities” in the UK
- specified foreign-power controlled entities to register any “relevant activities” that they carry out themselves in the UK.
Details of the foreign powers and entities which have been specified on the enhanced tier are available.
What is meant by "direction"?
A “direction” may be given formally (e.g. by contract) or informally (e.g. via quid-pro-quo arrangement, where there is any exchange of value, action or forbearance).
What is meant by "relevant activities"?
In this context “relevant activities” means any activities carried out in the UK.
How much time do I have to register?
Registration is required within 10 calendar days of the direction being given by the specified foreign power or foreign power-controlled entity and before the “relevant activities” commence. It is an offence to carry out “relevant activities” in the UK before the arrangement has been registered.
The political influence tier requires individuals or organisations to register where they are directed by any foreign power (except the Republic of Ireland) to carry out, or arrange for someone else to carry out, political influence activities in the UK.
Under FIRS, a foreign power includes:
- the sovereign or other head of a foreign state,
- a foreign government, or part of a foreign government (for example, a ministry or department of a foreign government);
- an agency or authority of a foreign government, or of part of a foreign government (for example, a police force or military of a foreign government),
- 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);
- a political party which is a governing political party of a foreign government.
A “direction” may be given formally (e.g. by contract) or informally (e.g. via quid-pro-quo arrangements, where there is any exchange of value, action or forbearance).
Political influence activities include:
- Communications made to senior public officials or politicians (e.g. emails, meetings)
- Public Communications (e.g. publication of articles)
- Disbursements (e.g. provision of goods or services)
Where the above are in each case intended to influence one or more 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
There are a number of exemptions set out on the HMG website here: guidance on the political influence tier.
FIRS Impact on Imperial
It is expected that FIRS will have relatively limited impact on core activities at Imperial. However, it will remain important for staff and students to consider whether any opportunities currently being pursued or under contemplation may fall within scope of FIRS, given the strict obligation to register those within the timeframes set out. For arrangements within the Enhanced Tier, registration must be completed prior to commencement.
What is Imperial’s position on FIRS?
As with all its legal obligations, Imperial regards a suitably informed, responsible, and legally compliant approach to national security considerations and requirements as indivisible from its academic mission, strategy and values. Equally, individual staff who are overseeing or undertaking activities, in particular Principal Investigators and Doctoral Supervisors, have responsibility for ensuring compliance with applicable legislation concerning national security. Consideration should be given to national security during the planning and conduct of Imperial activities, including consulting the published guidance. Subsequent information will be published on how Imperial will conduct registrations in scope.
Further advice may also be sought from the Research Security team within Imperial's Research Office: Contact us | Research | Imperial College London
Additional Government guidance on FIRS: FIRS – guidance for academia.