Application workflow to prevent registration support organizations from violating the Administrative Scrivener Act.
Registration support organizations must operate in a way that does not violate both the Administrative Scrivener Law and the Immigration Control Law when supporting foreign nationals in their residency status applications. In particular, the points of "who can create documents within what scope" and "who can act as an intermediary for immigration applications" are easily misunderstood, and violating them can lead to serious risks.
This article explains the basic points for registration support organizations to lawfully process residency status procedures, taking into account the Administrative Scrivener Law amendment that will be enforced on January 1, 8th year of Reiwa.
**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 to be 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, 8th year of Reiwa):
- The phrase "receiving compensation for accepting requests from others, regardless of the pretext" will be added to the text.
- This means that providing paid document creation under names like "consulting fees" or "administrative fees" may be considered illegal after the 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 approved institutional staff can submit residency status applications on behalf of the individual.
- If a registration support organization has obtained approval, the intermediary by staff is legal, but creating documents for a fee would violate the Administrative Scrivener Law.
- It is crucial to always separate "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 "administrative fees."
- Despite the pretext, creating immigration submission documents is illegal after the Reiwa 8th year amendment.
2. Cases including application agency in a "full-service package":
- Contracting for document creation and submission agency for residency status applications under names like "foreign employee recruitment support package" or "full registration support service."
- Since part of the service falls under the exclusive business of administrative scriveners, the entire package is at risk.
**RakuVisa Mechanism: 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.
Furthermore,
- Constantly updated to the latest format through immigration API integration.
- A mechanism where administrative scriveners are always involved in the application flow (excluding self-plans where foreign individuals apply themselves).
This allows registration support organizations to use RakuVisa with peace of mind even after the Administrative Scrivener Law amendment.
**Conclusion: Understand the Amended Administrative Scrivener Law Correctly and Operate Lawfully**
- The Administrative Scrivener Law amendment (enforced in the 8th year of Reiwa) has made paid document creation under names like "consulting fees" illegal.
- Registration support organizations need to clearly distinguish between "support tasks" and "application tasks" to avoid risks.
- RakuVisa's design of user input + administrative scrivener intermediary allows for safe use even after the legal amendment.
In the future, the mindset of "a little should be fine" may no longer be valid. Registration support organizations are likely to need to review laws such as the Immigration Control Law and the Administrative Scrivener Law, prioritize compliance, and establish a secure support flow for business continuity.

JP