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25 Nov 2025

Edward Grange writes comment piece for The Times Law section on the UK’s new Foreign Influence Registration Scheme

Partner Edward Grange has written a comment piece for The Times Law section on the UK’s new Foreign Influence Registration Scheme (FIRS).

There are fears that, in pursuing legitimate objectives, Ed says, FIRS risks chilling lawful activity, overburdening compliance frameworks and stigmatising benign engagement.

Under the “political tier”, the scheme requires individuals or businesses who conduct “political influence activities” in the UK at the direction of a foreign power, to register their arrangements on a public Home Office database within 28 days.

The “enhanced tier” requires those conducting any activity in the UK at the direction of a specified foreign power deemed to present an “elevated security risk” – currently Russia and Iran – to register within ten days of the agreement and before activities begin.

While the political tier is measured and aligned with international practice, Ed says, the enhanced tier risks sweeping up routine commercial or academic activity alongside malign influence.

Ambiguity over the concept of “direction” leaves organisations second-guessing whether they risk criminal liability and having to seek legal advice, Ed says.

Furthermore, he notes, the register’s public nature raises acute reputational concerns.

For organisations in sensitive sectors such as law, consultancy or academia, Ed suggests, the impression given by appearing on a register of “foreign influence” may be damaging, even when the underlying activity is benign.

FIRS marks a “significant shift” in the UK’s approach to national security and transparency, Ed says. While its aims are credible and enforcement powers strong, its design raises concerns over proportionality and the risk of collateral damage.

Read the full article in The Times.

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