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 applying for residency status.
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 proceed with residency status procedures, taking into account the Administrative Scrivener Act amendment that came into effect on January 1, 2026.
**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 Law (Enforced on January 1, 2026):
- The phrase "receiving compensation for accepting the request of others, regardless of the reason" will be added to the text.
- This means that providing paid document creation under names such as "consulting fees" or "office fees" will likely be considered illegal after the 2026 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 approved institution employees can submit residency status applications on behalf of individuals.
If a registration support organization has obtained approval, employee intermediaries are legal, but creating documents for compensation violates the Administrative Scrivener Act.
It is crucial to always differentiate "who creates and who submits."
**Common Risks in Registration Support Organizations (Specific Examples)**
1. Violation under a different name:
- Requesting payment for document creation under names like "application support fees," "consulting fees," or "office fees."
- Despite the name, creating immigration submission documents is illegal after the 2026 amendment.
2. Cases including application agency in a "full-service package":
- Contracting for document creation and submission agency for residency status under names like "foreign employee recruitment support package" or "registration support full service."
- Since some tasks fall under the exclusive work of administrative scriveners, the entire package is at risk.
**RakuVisa System: 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 submission are generated by administrative scriveners through the system during application intermediation.
- The phase where users create application forms themselves does not exist, avoiding the risk of violating the Administrative Scrivener Act.
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.
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 (enforced in 2026) has made paid document creation illegal under names like "consulting fees."
- Registration support organizations need to clearly distinguish between "support tasks" and "application tasks" to avoid risks.
- RakuVisa's design of user input + administrative scrivener intermediation 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 Act and the Administrative Scrivener Act, prioritize compliance, and establish a secure support flow for business continuity.

JP