Support organization registration application workflow to prevent administrative scrivener law violations.

What has changed with the amendment of the Administrative Scrivener Act With the expansion of the Specific Skills System, the number of applications handled by registration support organizations is increasing year by year. In the midst of increasing workload, many may be feeling uncertain about whether their application workflow is legally sound and where the violation of the Administrative Scrivener Act begins. The amended 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 amended 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 amendment, Article 19 of the Administrative Scrivener Act prohibited individuals who are not administrative scriveners from "receiving compensation" for document preparation. However, because the scope of "compensation" was ambiguous, in practice, there was a widespread interpretation that one could avoid violations by changing the name. Key Point: The amended law added the phrase "regardless of the name, receiving compensation" to Article 19. Even if it is under the names of "consulting fees," "office fees," or "application support fees," if there is actual document preparation, there is a higher likelihood of it being evaluated as illegal. Of particular note is 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 amendment, 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 organization itself as a legal entity may be subject to punishment. Common Violation Patterns in Registration Support Organizations Pattern 1: Including document preparation fees in support fees Pattern 2: Creating application documents under the guise of "consulting" Pattern 3: Providing a full-service package that includes document preparation Attention: While these patterns may have been considered acceptable in the past, with the enforcement of the amended law, business flows that were previously considered gray areas are now more likely to be clearly evaluated as violations. Establishing a Compliance System in 3 Points Point 1: Establish a system where document preparation is entrusted to an administrative scrivener Point 2: Clearly differentiate between types of compensation Point 3: Record and document the workflow RakuVisa: Realizing a Compliance System Using RakuVisa 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 ensures that document generation and API applications can only be executed with an administrative scrivener account. 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 function to automatically record and save online interviews between administrative scriveners and applicants, ensuring evidence of the independent judgment of the administrative scrivener in the process. The API application button is only enabled when the online signature and eKYC (identity verification) confirmation of the applicant are completed in conjunction with the interview. Moreover, the invoice and receipt clearly distinguish between administrative scrivener compensation and system usage fees, avoiding the risk of mixed compensation. 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 Article 7 of the Industrial Competitiveness Enhancement Act (dated February 6, 2022). Conclusion With the enforcement of the amended 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 double penalty provision extends penalties to corporations. To establish a lawful business structure, it is important to entrust document preparation to an administrative scrivener, clearly differentiate compensation, and maintain a workflow as evidence. Establishing a system to work in collaboration with administrative scriveners is the foundation for the continuity and trust of registration support organizations.