Application workflow to prevent registration support organizations from violating the Administrative Scrivener Act.

The number of application cases handled by registration support organizations is increasing year by year due to the expansion of the Specified Skilled Worker System. In the midst of increasing workload, many may feel anxious about whether their application workflow complies with the law or where the violation of the Administrative Scrivener Act begins. The revised Administrative Scrivener Act, which came into effect in January 2026, significantly strengthened the scope of violations and penalties. This article explains the key points of the revised law that registration support organizations should be aware of, common violation patterns that occur in the field, and how to establish a compliant compliance system. Before the revision, Article 19 of the Administrative Scrivener Act prohibited non-administrative scriveners from "receiving compensation" for document preparation. However, because the scope of "compensation" was ambiguous, in practice, there was a wide interpretation that one could avoid violations by changing the name. Point: The revised law added the phrase "regardless of the name, receiving compensation" to Article 19. Even if it is called "consulting fees," "office fees," or "application support fees," if there is actual document preparation, there is a higher likelihood of being evaluated as illegal. Furthermore, it is worth noting the establishment of the "double penalty provision" (a system where penalties apply to corporations as well). Previously, only individuals who committed violations were subject to punishment, but after the revision, corporations themselves are also subject to penalties. This means that if a staff member of a registration support organization violates the Administrative Scrivener Act, not only the individual staff member but also the corporation itself may be subject to punishment. Pattern 1: Including document preparation fees in support fees Pattern 2: Creating application documents under the name of "consulting" Pattern 3: Providing a full-service package that includes document preparation Attention: All of these patterns may seem to have been carried out without problems in the past. However, with the enforcement of the revised law, business flows that were previously considered gray areas are now more likely to be clearly evaluated as violations. To establish a lawful business structure, it is important to establish a workflow where document preparation is entrusted to an administrative scrivener, clearly differentiate between fees, and record and document the workflow. Point 1: Establish a system where document preparation is entrusted to an administrative scrivener Point 2: Clearly differentiate between fees Point 3: Record and document the workflow RakuVisa is an application platform for residence status that incorporates compliance requirements into its system design. It realizes the appropriate division of roles between registration support organizations and administrative scriveners as a mechanism. Specifically, the design allows only administrative scriveners to execute document generation and API applications. The editing rights of registration support organizations are limited to factual information about foreigners, affiliated organizations, and the registration support organization itself. This structurally eliminates the risk of "registration support organizations creating documents." Additionally, the system includes a feature to automatically record and save online interviews between administrative scriveners and applicants, ensuring evidence of independent judgment by the administrative scrivener in the process. The API application button is only enabled when the online signature and eKYC (identity verification) for applicant consent confirmation are completed along with the interview. Furthermore, the invoice and receipt clearly distinguish between administrative scrivener fees and system usage fees, avoiding the risk of fee mixing. Point: RakuVisa has obtained a response from the Ministry of Internal Affairs and Communications stating that "the provision of the system will not be evaluated as handling the affairs specified in Article 1-2, Paragraph 1 of the Administrative Scrivener Act as a business" through the Gray Zone Elimination System based on the Industrial Competitiveness Enhancement Act, dated February 6, 2022. In conclusion, with the enforcement of the revised Administrative Scrivener Act, the compliance risks for registration support organizations in residence status application business have increased significantly. "Regardless of the name," receiving compensation for document preparation is now subject to regulation, and the introduction of the double penalty provision means that penalties also apply to corporations. To establish a lawful business structure, it is important to entrust document preparation to an administrative scrivener, clearly differentiate between fees, and record and document the workflow. Establishing a system to handle tasks lawfully in collaboration with administrative scriveners is the foundation for the continued operation and trust of registration support organizations.