Application workflow to ensure that registration support organizations do not violate the Administrative Scrivener Act.
Registration support organizations must operate in a way that does not violate the Administrative Scrivener Law and the Immigration Control Law when supporting foreign nationals in applying for residency status. In particular, the points of "who can create documents within what scope" and "who can act as an intermediary with immigration" are easily misunderstood and can pose significant risks if violated.
This article explains the basic points for registration support organizations to lawfully proceed with residency status procedures, taking into account the Administrative Scrivener Law amendment that will be enforced from January 1, Reiwa 8 (2026).
**Administrative Scrivener Law Basics and Amendment Content**
Current Law:
- According to Article 1-2 of the Administrative Scrivener Law, only administrative scriveners can receive compensation for creating documents submitted to government offices.
- It is illegal for employees of registration support organizations to receive compensation for creating immigration submission documents.
Amendment Law (Enforced on January 1, Reiwa 8):
- The phrase "receiving compensation for accepting the request of others, regardless of the pretext" will be added to the text.
- This makes it highly likely that providing paid document creation under names such as "consulting fees" or "office fees" will be considered illegal after the 2026 amendment.
**Immigration Control Law Basics: Entities that can act as intermediaries for applications**
- Under the Immigration Control Law, only administrative scriveners with application intermediary qualifications or authorized institution employees can submit residency status applications on behalf of the individual.
- If a registration support organization has obtained approval, intermediary services by employees are lawful, but creating documents for a fee would violate the Administrative Scrivener Law.
- It is crucial to always distinguish "who creates and who submits" documents.
**Common Risks in Registration Support Organizations (Specific Examples)**
1. Violation under a different pretext:
- Charging for application document creation under names like "application support fees," "consulting fees," or "office fees."
- Despite the pretext, creating immigration submission documents would be illegal after the Reiwa 8 amendment.
2. Cases including application agency in the "full service":
- Contracting for document creation and submission agency for residency status under names like "foreign employee recruitment support package" or "registration support full service."
- Since part of the service falls under the exclusive business of administrative scriveners, the entire package poses a risk.
**RakuVisa System: Design to Avoid Administrative Scrivener Law Violations**
RakuVisa for TSK is designed with compliance as the top priority.
- Users (foreign individuals, affiliated institutions, registration support organizations) only need to input data into the form.
- Official application documents for immigration submission are generated by administrative scriveners through the system during application intermediary.
- The phase where users create application forms does not exist, avoiding the risk of violating the Administrative Scrivener Law.
Additionally,
- Constantly updated to the latest format through immigration API integration.
- The application flow involves administrative scriveners (excluding self-plans where foreign individuals apply themselves), ensuring compliance.
By following the revised Administrative Scrivener Law correctly, registration support organizations can continue to use RakuVisa with peace of mind.

JP