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

What has changed with the revised Administrative Scrivener Law As the Specific Skills System expands, the number of applications handled by registration support organizations is increasing year by year. Amidst the increasing workload, many may feel anxious about whether their application workflow is legally sound and where the violation of the Administrative Scrivener Law begins. The revised Administrative Scrivener Law, which came into effect in January 2026, significantly strengthened the scope of violations and penalties. This article explains the key points of the revised 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 revision, Article 19 of the Administrative Scrivener Law prohibited non-administrative scriveners from "receiving compensation" for document preparation. However, because the scope of "compensation" was ambiguous, the interpretation that one could avoid violations by changing the name was widespread in practice. Key Point: The revised law added the phrase "regardless of the name, receiving compensation" to Article 19. Even if it is labeled as "consulting fees," "administrative fees," or "application support fees," if there is actual document preparation, it is more likely to be evaluated as illegal. Of particular note is the establishment of the "double penalty provision" (a system where penalties also apply to corporations). Previously, only individuals who committed violations were subject to punishment, but after the revision, corporations themselves can also be subject to penalties. This means that if a staff member of a registration support organization violates the Administrative Scrivener Law, not only the individual staff member but also the organization itself 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 guise of "consulting" Pattern 3: Providing a full-service package that includes document preparation Attention: While these patterns may have been perceived as problem-free in the past, with the enforcement of the revised 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 types of compensation Point 3: Record and document the workflow RakuVisa: Realizing 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. Specifically, the design ensures that document generation and API applications can only be executed with an administrative scrivener account. The editing permissions of registration support organizations are limited to factual information about foreigners, affiliated organizations, and the 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 consultations between administrative scriveners and applicants, ensuring evidence of independent judgment by the administrative scrivener. The API application button is only enabled when online signatures and eKYC (identity verification) for applicant consent confirmation are completed alongside the consultation. Additionally, the invoice and receipt clearly distinguish between administrative scrivener fees 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 Law 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 revised Administrative Scrivener Law, the compliance risks for registration support organizations in residence status application operations 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. Aligning with an administrative scrivener to process tasks lawfully is the foundation for the continued operation and trust of registration support organizations.