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 can pose significant risks if violated. This article explains the basic points for registration support organizations to lawfully process 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 "administrative fees" will be considered illegal after the 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 violates 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 "administrative fees." - Despite the pretext, creating immigration submission documents is illegal, especially after the Reiwa 8 amendment. **2. Confusion between internal documents and submission documents** - Creating support plans or employment contracts internally is not an issue, but providing them to customers as official immigration submission forms and receiving compensation violates the Administrative Scrivener Act. **3. Cases where application agency is included in the "full service" package** - Contracting for services like "foreign employee recruitment support package" or "registration support full service," including document creation and submission agency for residency status. - As part of the service falls under the exclusive business of the Administrative Scrivener Act, the entire package is at risk. **RakuVisa Mechanism: Design to Avoid Violating the Administrative Scrivener Act** RakuVisa for TSK is designed with compliance as the top priority. - Users (foreign individuals, affiliated institutions, registration support organizations) only need to input information into the form. - Official immigration submission documents 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 Act. Additionally, - Constantly updated to the latest format through immigration API integration. - The application flow involves administrative scriveners without fail (excluding self-plans where foreign individuals apply themselves). This allows registration support organizations to use RakuVisa with peace of mind even after the amendment to the Administrative Scrivener Act. **Conclusion: Understand the Amended Administrative Scrivener Act Correctly and Operate Lawfully** - The Administrative Scrivener Act amendment (effective Reiwa 8) criminalizes 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 secure support flow for business continuity.