National Security Bill: Foreign Influence Registration Scheme

15 December 2022

We welcome the objectives of the National Security Bill, however we believe the proposed Foreign Influence Registration Scheme (FIRS) must complement existing protections and avoid introducing duplicative and bureaucratic requirements, which would divert resource from focusing on genuine threats.

Our members understand that working with international partners is not without risk and take their responsibilities to protect national security seriously. Therefore we work with the Government and security agencies to ensure existing legislative and regulatory safeguards are used effectively to protect the UK from those seeking to take advantage.

The Government already has oversight over a range of universities' international activities (e.g. through the visa system and export controls) and we are concerned that additional reporting could duplicate existing regulation while adding little value to the current system of safeguards and protections.

The requirements of the enhanced tier of the UK FIRS could include a range of international activities from student exchange programmes to research partnerships, many of which are already covered in existing legislation. The potentially duplicative and complex nature of this arrangement could limit opportunities for genuine international collaboration and risk deterring global partners, which would in turn hinder national and local R&D led growth.

If university activity is to be captured, we believe the following steps would mitigate those risks and ensure the sector's resources are focused on genuine threats, rather than needless form filling.

  1. Dedicated, co-created university guidance describing the arrangements to be captured

  2. Targeted exemptions for arrangements which Government is already aware of through existing protections such as export control, the National Security and Investment Act, or by virtue of providing grant funding.

  3. Exempting unfunded academic partnerships or philanthropic donations

  4. No retrospective reporting, which has been a feature of equivalent systems in other countries but was quickly found to be unworkable because of the bureaucratic burden leading to many arrangements not being reported.

  5. Ensure the list is strictly private and to respect commercial confidentiality

National Security Bill (FIRS) Lords Second Reading Briefing.pdf

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