For many PR agencies, the language of lobbying registers and regulatory compliance is familiar. But the implications of FIRS run deeper than a bureaucratic formality. It signals a shift in how the UK government perceives influence, especially when that influence is directed from abroad.

At its core, FIRS is about transparency. Under the scheme, individuals or organisations instructed by a foreign state or a foreign state-controlled body must register their activities in the UK if they seek to influence political decisions, elections, or registered political parties. The rules are not merely advisory. A public register will make these affiliations visible. PR firms working for foreign governments or their proxies are now expected to declare their interests, or risk breaching national security laws.

What matters here is not just what FIRS says, but what it implies: that the UK sees foreign influence without transparency as a risk. 

What Is the Foreign Influence Registration Scheme?

The Foreign Influence Registration Scheme was introduced through the UK’s National Security Act 2023, passed in response to rising geopolitical threats and increased use of non-military influence operations by foreign governments. According to the Home Office guidance, FIRS is split into two tiers:

• Political Influence Tier: Applies to activities conducted under the direction of any foreign state to influence UK political decisions, elections or referenda. 
• Enhanced Tier: Applies where such activities are directed by a foreign state or state-controlled organisation specified by the Secretary of State as high risk.

Activities in scope include communications with ministers or MPs, public media campaigns, and the provision of services aimed at shaping political outcomes.

Why Governments Are Introducing Foreign Agent Registries

The British government is not alone in rethinking foreign influence:

• In the United States, the Foreign Agents Registration Act (FARA) requires disclosure of foreign lobbying and PR – Established in 1938 
• Australia passed its Foreign Influence Transparency Scheme in 2018
• The European Union has its own Transparency Register. – Established in 2011

These governments are responding to the increased use of State-sponsored disinformation to destabilise democratic institutions.

The United States’ Senate Intelligence Committee confirmed that the Russian Internet Research Agency (IRA) interfered in the 2016 U.S. election, reaching 126 million Facebook users and generating over 10 million tweets to divide the electorate.

In the UK, the Intelligence and Security Committee’s Russia Report published in July 2020 warned of “credible open source commentary suggesting that Russia undertook influence campaigns in relation to the Scottish independence referendum in 2014.” The committee added that British intelligence agencies “took their eye off the ball.”

How Foreign Influence Intersects with the PR Industry

The public relations profession is built on the capacity to shape public opinion. That makes it a natural target for foreign governments seeking to project soft power or manipulate policy narratives in liberal democracies.

FIRS explicitly mentions PR-related activities in its guidance for the sector. Public communications, from social media to newspaper op-eds, may fall under registration requirements if they are conducted under the instruction of a foreign state. So too might lobbying of MPs or ministers, even indirectly, if the activity is commissioned by a foreign entity.

This includes think tanks, consultancies and even academic partnerships. Many such engagements may appear benign on the surface, but may be part of more complex influence strategies.

Risk Management and Ethical Due Diligence in PR

This is no longer just a legal issue. It is a reputational risk and a test of ethical discipline. PR consultancies that represent clients without fully understanding their funding structures, affiliations or political intentions expose themselves to backlash from staff, regulators and the public.

The CGTN case in the UK is instructive. In 2021, Ofcom revoked the UK licence of the Chinese state broadcaster, citing direct control by the Chinese Communist Party. Prior to this, CGTN had collaborated with Western media strategists and content consultants to improve its image in Europe. These partnerships were subsequently viewed in a more critical light.

FIRS now makes explicit what was once implied: agencies must ask more questions. Who is the beneficial owner? Is this communication clearly attributed? Does the campaign seek to influence UK political decisions? If the answers involve a foreign state actor, registration under FIRS may be legally required. 

Jon Gerlis, Head of PR and Policy at the Chartered Institute of Public Relations (CIPR), believes the introduction of FIRS marks an important shift in professional accountability.

“The Foreign Influence Registration Scheme is a welcome attempt to increase transparency and, in turn, reassure the public about the interests of lobbyists and who they represent. It puts the UK in line with other countries that operate similar registers and demonstrates a recognition that lobbying is a vital part of our democracy, but must come with a responsibility to be accountable. The CIPR will be keeping a close eye on how effective the register proves and how the public relations industry adapts to it.”

What UK PR Firms Should Do to Stay Compliant

Firms must now build FIRS compliance into their KYC due diligence checks on incoming briefs,  client onboarding, and regular checks throughout the engagement.  This includes:

• Conducting foreign principal checks on new clients 
• Keeping records of instructions and communications 
• Declaring influence activities via the online registration portal 
• Aligning legal counsel and account teams to identify FIRS-related risk early 

Most importantly, agencies should adopt a policy of transparency by default. If a campaign is funded or directed by a foreign government, it should be clearly attributed in all relevant public-facing content. This not only satisfies FIRS exemptions but protects the agency’s long-term credibility.

FIRS is unlikely to be the final word. As global tensions rise, governments are tightening rules on cross-border influence and investing in counter-disinformation capabilities. The UK’s Online Safety Act, EU Digital Services Act, and expanding regulatory scrutiny from watchdogs like Ofcom suggest that public communications, especially by foreign actors, will be under continued observation.

For PR professionals, this demands a new mindset. Influence is no longer neutral. It carries political weight. In this context, transparency is increasingly no longer a legal requirement; it is becoming business as usual. 

Curzon PR is a London-based PR firm working with clients globally. If you have any questions, please feel free to contact our Business Development Team bd@curzonpr.com