Workflow for application tasks to prevent registration support organizations from violating the Administrative Scrivener Act.
Registration support organizations must operate in a way that does not violate 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 with the immigration authorities" are easily misunderstood, and violating them can pose significant risks.
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 will be enforced on January 1, 8th year of Reiwa.
**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 and create documents for submission to immigration authorities.
Amendment Law (Enforced on January 1, 8th year of Reiwa):
- 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 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 institutional staff can submit residency status applications on behalf of the individual.
- If a registration support organization has obtained approval, the intermediary by staff is 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 document creation under names like "application support fees," "consulting fees," or "office fees."
- Despite the pretext, it is illegal after the Reiwa 8th year 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 "full registration support service."
- 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 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 intermediary.
- The phase where users create application forms does not exist, avoiding the risk of violating the Administrative Scrivener Act.
Furthermore,
- Constantly updated to the latest format through immigration API linkage.
- The application flow involves administrative scriveners (excluding self-plans where foreign individuals apply themselves), ensuring compliance.
By following these measures, registration support organizations can safely use RakuVisa even after the Administrative Scrivener Act amendment, ensuring compliance and secure support flow.

JP