Executive Summary
- What’s new: In 2025, five states — Arkansas, Louisiana, Nebraska, Oklahoma and Texas — adopted foreign-influence laws that require disclosure of lobbying and other advocacy activities conducted on behalf of certain foreign principals.
- Why it matters: Foreign companies — and even in some cases U.S. subsidiaries of foreign companies and other U.S. companies with foreign ownership — may be subject to onerous registration and reporting requirements under these laws.
- What to do next: Companies engaged in lobbying or other advocacy activities in these five states should determine whether they trigger registration or disclosure obligations under any of these “FARA-lite” laws.
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States are increasingly enacting so-called foreign-influence laws, which generally fall into one of two categories: some are designed to restrict foreign political spending — extending beyond or restating the ban on contributions and expenditures by foreign nationals under federal election law — while others, modeled in part on the federal Foreign Agents Registration Act (FARA), require disclosure of lobbying and other advocacy activities conducted on behalf of foreign principals, such as foreign governments or companies. This year, five states — Arkansas, Louisiana, Nebraska, Oklahoma and Texas — adopted the latter type of foreign-influence laws.
These new laws extend beyond the scope of FARA in several important respects. Notably, they lack the helpful exemptions under FARA, on which many rely when advocating for interests of a foreign company, such as the commercial exemption or an exemption — analogous to FARA’s Lobbying Disclosure Act exemption — for those registered under a state’s lobbying law. Also, some of these state laws treat U.S. subsidiaries, and even entities with certain amounts of foreign ownership, as foreign principals. As a result, advocating for a U.S. subsidiary of a foreign company or other foreign-owned U.S. entity is treated the same as advocating for the foreign parent or foreign owner. Additionally, the Texas law extends beyond FARA as well as the other four state laws in that it not only requires a person who lobbies on behalf of a covered foreign principal to register; it also, on its face, prohibits the lobbyist from receiving any compensation from such foreign principal. However, with the exception of Oklahoma’s law, these state laws are limited to foreign principals from “hostile” countries, such as China, Iran, North Korea and Russia. Below is a summary of these new laws.
Arkansas
The Arkansas law, which took effect on August 5, 2025, requires a representative of a foreign principal from a “hostile foreign nation” — i.e., China, Iran, North Korea or Russia — that engages in political activity within the state to register with the Arkansas Secretary of State’s Office and file quarterly updates. “Hostile foreign principals” include Chinese, Iranian, North Korean and Russian companies, as well as governments, political parties and certain individuals from those countries. Political activity means attempting to influence state or local officials or the public regarding state laws, policies or the election of state or local candidates, excluding making campaign contributions.
A “foreign-supported political organization” — i.e., any organization (i) that has received a thing of value from a “hostile” foreign principal or that principal’s representatives within the last five years and (ii) that engages in political activity within the state — is required to register and file annual updates. This is a broad definition, given the “thing of value” received from a foreign principal need not be for Arkansas political activity. However, a proposed rulemaking would helpfully limit “thing of value” in the foregoing definition to “donations.” This would clarify that entities that merely receive funds in the ordinary course of business from covered foreign persons and that separately engage in Arkansas political activity are not subject to this registration requirement.
Louisiana
The Louisiana law, which takes effect on December 1, 2025, requires a person who engages in any legislative lobbying on behalf of a “designated foreign corporation” from a foreign adversary nation or a “foreign adversary” to file a disclosure with the Louisiana Board of Ethics describing the foreign principal and lobbying activity. This is separate from the state’s registration requirement for legislative branch lobbyists and, on its face, applies even if a person does not meet the state’s registration thresholds for legislative lobbying. A “designated foreign corporation” is a foreign corporation or other entity organized or headquartered in a nation identified as a foreign adversary. Foreign adversaries are (i) the governments identified in 15 C.F.R. § 791.4 (currently China, Cuba, Iran, North Korea and Russia, as well as the Maduro Regime of Venezuela) as well as (ii) the individuals, corporations or governments identified in the “database maintained by the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC),” which presumably is a reference to the OFAC Sanctions List.
Separately, registered executive-branch lobbyists and local-level lobbyists for foreign adversaries — but not those for designated foreign corporations — must also file the foreign adversary notice described above.
Nebraska
The Nebraska law, which took effect on October 1, 2025, requires an agent of a foreign principal from an “adversary nation” — i.e., China, Cuba, Iran, North Korea, Russia or the Maduro Regime of Venezuela — that engages in covered activity within the state to publicly register with the Nebraska Attorney General’s Office and file semiannual reports thereafter. Foreign principals are broadly defined and include, among others, companies organized or headquartered in an “adversary nation” and entities in which such companies have a beneficial ownership interest of at least 20%. Similar to FARA, covered activity means engaging in political activity; serving as a public relations counsel, publicity agent, information-service employee or political consultant; soliciting or disbursing funds or things of value; or representing a foreign principal’s interests before Nebraska state or local officials. However, the Nebraska Attorney General’s Office issued FAQs that appear to limit covered activities generally to attempting to influence Nebraska state or local officials or members of the Nebraska public regarding policy or elections.
The Nebraska law is an expansive law, which also notably prohibits a “foreign adversarial company” from receiving any state financial incentive created for the purpose of recruiting or retaining business in the state. A foreign adversarial company means a company organized or headquartered in an adversarial nation (i.e., a country listed in 15 C.F.R. 791.4, which currently is limited to the countries listed above); a company owned in whole or in part, operated or controlled by the government of a foreign adversary; and any parent company or subsidiary of such entities.
Oklahoma
The Oklahoma law, which took effect on November 1, 2025, requires an individual attempting to influence state laws or the award of state funds on behalf of a foreign company or a company that is at least 51% foreign-owned to publicly register as an international corporation agent with the Oklahoma Secretary of State’s Office if they receive any compensation for such activity. Unlike the foreign-influence laws in the other four states, this law is not limited to advocacy on behalf of foreign principals from countries deemed “hostile” to the U.S. The Oklahoma Secretary of State’s Office has not yet issued the registration form or any guidance on its website.
Texas
The Texas law, which took effect on September 1, 2025, amends the state lobbying law to require a person who engages in any lobbying on behalf of a foreign adversary, foreign adversary client or foreign adversary political party to publicly register as a Texas lobbyist, even if they would not otherwise trigger registration under the state’s compensation or expenditure thresholds. The Texas law is also targeted at nations identified in 15 C.F.R. § 791.4 (currently China, Cuba, Iran, North Korea, Russia and the Maduro Regime of Venezuela). The law covers a wide range of foreign principals, including but not limited to companies organized or headquartered in the foregoing nations and their subsidiaries.
The law also prohibits a lobbyist from receiving any compensation from a foreign adversary, foreign adversary client or foreign adversary political party for which they lobby. Thus the law, on its face, prohibits in-house employees and paid outside consultants from lobbying in Texas on behalf of these foreign principals., However, whether the state will interpret this ban so broadly is unclear, given the constitutional concerns it raises, as described below.
Practical Implications
These laws reflect a broader and growing trend among states seeking to combat foreign influence. We expect this trend to continue in 2026, and there are already rumblings that other conservative-leaning states are considering similar “FARA-lite” bills. However, these laws may be vulnerable to legal challenges, as they present a number of constitutional concerns, including regarding separation of powers and whether a federal law such as FARA should preempt state laws when regulating foreign affairs. Also, Texas’ ban on compensation to lobbyists on behalf of covered foreign principals raises significant First Amendment concerns where it implicates the constitutional right to petition the government.
While such questions regarding these laws remain unresolved, companies are in the unenviable position of having to apply and comply with both FARA and FARA-lite laws. We will closely monitor the implementation of these laws, including for any regulations or guidance.
This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.