Legal Update - 1 July 2025
A number of SI’s come into force on 1 July 2025 in relation to the National Security Act 2023. Commencement Regulations SI 2025/674 brought into force Part 4 of the Act which concerns the introduction of a Foreign Activities and Foreign Influence Registration Scheme (FIRS). FIRS will 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.
The scheme aims to increase transparency of foreign power influence over the UK democracy and provide greater assurance about the activities of specified foreign powers, and specified entities controlled by foreign powers, which pose the greatest risk to the UK. It will do this by requiring individuals or organisations to register with the Secretary of State where they form certain arrangements with foreign powers or carry out certain activities in the UK. Four categories of activities or arrangements are required to be registered with the Secretary of State under the scheme:
(1) foreign activity arrangements (section 65),
(2) certain activities of persons specified in relation to the regime (section 68),
(3) foreign influence arrangements (section 69), and
(4) certain political influence activities of foreign powers where there is misrepresentation (section 72).
Upon registration, information specified in the National Security Act 2023 (Foreign Activities and Foreign Influence Registration Scheme: Information and Disclosure) Regulations 2025, also in force from 1 July 2025, must be provided to the Secretary of State. Some, but not all, of that information is required to be published – see section 79 and the National Security Act 2023 (Foreign Activities and Foreign Influence Registration Scheme: Publication) Regulations 2025 for full details. This will therefore strengthen the integrity of UK politics and institutions and protect the UK from state threats.
The scheme is split into two parts: the “political influence tier” and the “enhanced tier”. The enhanced tier contains a power enabling the Secretary of State to specify foreign powers, or foreign power-controlled entities, where it is considered reasonably necessary to protect the safety or interests of the UK. Offences committed in breach of the requirements of the scheme carry a higher penalty in respect of the enhanced tier.
Sections 65-68 relate to the ‘enhanced tier’ of the FIRS. Section 65 introduces a requirement to register a "foreign activity arrangement" which is an agreement or arrangement between a person, "P", and a “specified person” where a "specified person" directs "P" to carry out relevant activities in the UK, or arrange for others to carry out relevant activities in the UK.
Section 66 sets out the meaning of “specified person” as a foreign power or a person (other than a foreign power), specified by the Secretary of State in regulations. A foreign power is defined at section 32 of the Act (although the term is modified for the purpose of Part 4 of the Act by section 83).
Sections 69-72 relate to the political influence tier of the FIRS. Section 69 provides a requirement to register a "foreign influence arrangement" made with a foreign power and provides the meaning of a "foreign influence arrangement". It is an agreement or arrangement between a person, "P", and a foreign power under which a foreign power directs "P" to carry out political influence activities in the UK, or arrange for others to carry out political influence activities in the UK. Activities in the UK will, for example, include where communication is sent from overseas to the UK, as well as activities which take place entirely in the UK.
Part 4 of the National Security Act 2023 creates the following new offences:
- H101461 - Failure to register a foreign activity arrangement
- H101462 - Maker of unregistered foreign activity requirement carry out relevant activity
- H101463 - Carry out relevant activity under unregistered foreign activity arrangement
- H101464 - Specified person carry out unregistered relevant activity
- H101465 - Employee etc of specified person carry out unregistered relevant activity
- H101466 - Misrepresentation by employee etc of specified foreign power relating to unregistered relevant activity
- H101467 - Failed to register a foreign influence arrangement
- H101468 - Carry out activities under an unregistered foreign influence arrangement
- H101469 - Person other than maker carry out activities under unregistered foreign influence arrangement
- H101471 - Misrepresentation by employee etc of foreign power relating to unregistered political influence activity
- H101472 - Fail to notify Secretary of State of material change to information on a registered activity or arrangement
- H101473 - Fail to comply with information notice - foreign activity
- H101474 - Provide false information re foreign activity arrangement
- H101475 - Provide false information re registerable relevant activity
- H101476 - Knowingly provide false information re foreign influence arrangement
- H101477 - Knowingly provide false information re political influence activity
- H101830 - Fail to notify Secretary of State of material change to information on an influence activity or arrangement
- H101831 - Fail to comply with information notice - foreign influence
In conjunction with this scheme being brought into force, there have been two sets of regulations published which specify a number of both Russian and Iranian powers that will come under the enhanced tier provisions of the scheme. Please see the National Security Act 2023 (Foreign Activities and Foreign Influence Registration Scheme: Specified Persons) (Russia) Regulations 2025, and the National Security Act 2023 (Foreign Activities and Foreign Influence Registration Scheme: Specified Persons) (Iran) Regulations 2025.
Additionally, please see the government guidance in this area.
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