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Who's Speaking? The role of Foreign Influence and Registration schemes

Dr Lukasz Olejnik

Visiting Senior Research Fellow

05 June 2025

What if it’s not always clear who’s speaking—or who they’re speaking for? When it comes to communication or influence, the line between personal opinion, lobbying and foreign influence might often be blurred. Governments, media outlets, universities and NGOs operate in an environment where foreign powers can quietly shape public debate and policy without obvious disclosure.

One common method is through agents d’influence—individuals or groups strategically used to sway opinions or actions, often without their true affiliations being obvious. This concept isn’t new; even Voltaire, whose satirical writings attacked social and judicial structures, might be seen as an early example. But today’s information landscape is far more complex than it was 10 years ago, let alone 250.

Imagine you’re a paid lobbyist, propagandist, or agent of influence openly acting on behalf of a foreign power. Most readers would reasonably assume that what you write isn’t entirely your own—it's shaped, directed or even financed by another state. That instinct is understandable: we tend to place more trust in voices that appear independent and unaffiliated. If an article or public statement came with a label such as "paid agent of a foreign intelligence service," we’d interpret it very differently. Yet, let’s be clear—such transparency is the exception, not the rule. So, what can be done in an age where foreign influence rarely announces itself?

There are several ways to address this challenge. One approach is a self-declared registration. The United Kingdom has introduced the Foreign Influence Registration Scheme (FIRS), which requires individuals and organisations to register if they are directed by a foreign power to carry out political influence activities. The scheme is structured around two tiers: the political influence tier and the enhanced tier.

Under the political influence tier, registration is required when foreign-directed actors engage in activities intended to influence UK political matters—including public relations, media communication, or the provision of money, goods or services—with the aim of swaying elections, referenda or governmental decision-making.

The enhanced tier has broader scope. It applies to activities conducted under the direction of designated foreign states or entities they control—even if the activities are not overtly political. These include commercial operations, academic research, service provision and participation in public events.

Influence registration doesn't stop with the media; it may also affect academic institutions, where scholarly authority can shape public narratives as powerfully as journalism. While Recognized News Publishers (RNPs) are exempt from registration under the political influence tier, they are not exempt under the enhanced tier. If a journalist or media outlet operates at the instruction of a specified foreign power, they must register if they engage in activities such as publishing reports, producing videos, conducting interviews or carrying out investigative journalism. Freelance journalists may also fall under the registration requirement, depending on their arrangements.

For instance, imagine a UK-based news platform that signs an agreement with the Russian embassy to publish articles enhancing Russia's cultural image and indirectly shaping diplomatic perceptions. If the platform fails to disclose this arrangement, it may be required to register under the political influence tier. Or consider a freelance journalist contracted by a state-owned broadcaster from a designated country. If their work aligns with foreign messaging priorities and is produced under instruction, they may be subject to the enhanced tier.

Academic institutions are not exempt either. A university that accepts funding from a foreign government to lobby for visa reforms in exchange for student recruitment must register. Similarly, if a research funding comes with a condition to advocate for a legislative change, or to arrange visas for foreign officials ostensibly visiting for research consultation, these activities may trigger registration obligations.

The same rules apply to non-governmental organisations. If an NGO receives foreign funding alongside instructions to lobby public bodies, registration is mandatory.

Comparable frameworks exist in other jurisdictions. The US Foreign Agents Registration Act (FARA) defines an "agent of a foreign principal" as a person acting on behalf of a foreign entity to influence US policy or public opinion. Canada has advanced its own foreign agent registry, while Russia enforces a stricter version of such legislation.

In the face of escalating information operations, the EU and the UK face increasing pressure to respond. The EU Commission has likewise moved toward a similar mechanism, which is currently advancing through the legislative process. Under the European Commission's proposal, institutional actors such as firms may face fines of up to 1% of their global turnover, and other legal entities may be fined up to 1% of their total annual budget. For natural persons, the original ceiling was set at just €1,000—suggesting that non-registration could appear cost-effective. The European Parliament responded by proposing an increase to a range between €1,000 and €5,000, depending on the gravity of the offence. Yet even €5,000 is unlikely to serve as a meaningful deterrent in cases of deliberate or well-resourced foreign influence activity. In other words, clandestine foreign influence would remain cost-effective.

As of now, the UK's enhanced tier applies to Russia and Iran. Registration is completed online.

Discussion around such systems must weigh the imperative of sovereignty protection against foundational democratic principles—including freedom of expression, academic autonomy and associational liberty.

Even so, it remains essential to distinguish between legitimate international cooperation and conduct that crosses legal or ethical boundaries. Not every tweet from a foreign head of state is a cause for alarm—but patterns of coordinated influence might well be.

Can such a system work? Perhaps. It may be useful in future legal proceedings, where a failure to disclose could be cited as an additional element in a case—particularly in situations where prosecution is otherwise difficult. But on its own, it is unlikely to be sufficient. Registration should be understood as one component of a broader, more holistic approach to addressing foreign influence.

Lukasz Olejnik is an independent researcher and consultant in cybersecurity and privacy, with a strong focus on multidisciplinary and interdisciplinary research.

He holds a PhD in Computer Science from INRIA, France, and an LLM in Information Technology Law from the University of Edinburgh. He integrates knowledge and skills from academia, industry, technology, research, policy and law. He is also the author of numerous scientific papers, policy reports and books on cybersecurity, privacy and technology.

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Lukasz  Olejnik

Lukasz Olejnik

Visiting Senior Research Fellow

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