Workflow for application tasks to prevent registration support organizations from violating the Administrative Scrivener Act.

What has changed with the amendment of the Administrative Scrivener Act With the expansion of the Specific Skills System, the number of application cases handled by registration support organizations is increasing year by year. In the midst of increasing workload, many may feel anxious 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 non-administrative scriveners from "receiving remuneration" for document preparation. However, because the scope of "remuneration" was ambiguous, the interpretation that one could avoid violations by changing the name was widespread in practice. Point: The amended law added the phrase "regardless of the name, receiving remuneration" to Article 19. Even if it is called "consulting fees," "office fees," or "application support fees," if there is actual document preparation, it is more likely to be evaluated as illegal. Another point to note is the establishment of a "double penalty provision" (a system where penalties also apply to corporations). 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. Three common violation patterns in registration support organizations 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 Caution: 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: Three Points Point 1: Establish a system where document preparation is entrusted to an administrative scrivener Point 2: Clearly differentiate between remuneration categories Point 3: Record and document the workflow RakuVisa for Building a Compliance System 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 application 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." Furthermore, the system includes a feature to automatically record and save online interviews between administrative scriveners and applicants, ensuring evidence of the independent judgment-based workflow. 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. Additionally, the invoice and receipt clearly distinguish between administrative scrivener remuneration and system usage fees, avoiding the risk of mixed remuneration. 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). Conclusion With the enforcement of the amended Administrative Scrivener Act, the compliance risks for registration support organizations in residence status application operations have increased significantly. "Regardless of the name," receiving remuneration for document preparation is now subject to regulation, and the establishment of a double penalty provision means that penalties also apply to corporations. To establish a lawful business system, it is important to entrust document preparation to an administrative scrivener, clearly differentiate remuneration, and record the workflow as evidence. Establishing a system to work in collaboration with administrative scriveners is the foundation for the continued operation and trust of registration support organizations.