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

Registration support organizations must operate in a way that does not violate both the Administrative Scrivener Act and the Immigration Control Act 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 with immigration" are easily misunderstood and can pose significant risks if violated. This article explains the basic points for registration support organizations to lawfully carry out residency status procedures, taking into account the Administrative Scrivener Act amendment that came into effect on January 1, Reiwa 8. **Administrative Scrivener Act Basics and Amendment Content** **Current Law** - According to Article 1-2 of the Administrative Scrivener Act, 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 (Effective January 1, Reiwa 8)** - The phrase "receiving compensation under any pretext upon receiving a request from another person" 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 8th year of Reiwa amendment. **Warning Point**: It is highly likely that providing document creation under the name of "support fees" will be interpreted as illegal after the amendment. **Immigration Control Act Basics: Entities that can act as intermediaries for applications** - Under the Immigration Control Act, 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 actions by employees are lawful, but creating documents for a fee would violate the Administrative Scrivener Act. - 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 "office fees." - Despite the pretext, creating documents for immigration submissions would be illegal after the Reiwa 8 amendment. 2. Cases including application agency in a "full-service package" - Contracting for document creation and submission agency under names like "foreign employee recruitment support package" or "registration support full service" alongside life support and recruitment agency services. - As part of the work falls under the exclusive work of administrative scriveners, the entire package poses a risk. **RakuVisa Mechanism: Design to Avoid Administrative Scrivener Act 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 submissions are generated by administrative scriveners through the system during application intermediary. - The phase where users create application documents does not exist, avoiding the risk of violating the Administrative Scrivener Act. 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 Act amendment. **Conclusion: Understand the Amended Administrative Scrivener Act Correctly and Operate Lawfully** - The Administrative Scrivener Act amendment (effective Reiwa 8) illegalizes paid document creation under names like "consulting fees." - Registration support organizations need to clearly distinguish between "support services" and "application services" to avoid risks. - With a design of user input + administrative scrivener intermediary, RakuVisa remains usable with peace of mind 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 Act and the Administrative Scrivener Act, prioritize compliance, and establish a safe support flow as a condition for business continuity.