Workflow for application tasks to prevent registration support organizations from violating the Administrative Scrivener Act.
What has changed in the revised Administrative Scrivener Act?
With the expansion of the specified skills system, the number of application cases handled by registration support organizations is increasing year by year. In the revised Administrative Scrivener Act implemented in January 2026, the scope of violations and penalties has been significantly strengthened. 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 Act prohibited individuals who are not administrative scriveners from engaging in document preparation "for remuneration." However, the interpretation in practice was that as long as the remuneration was changed in name, one could avoid violations.
The revised law added the phrase "regardless of the name, for remuneration" to Article 19. Even if it is under the names of "consulting fees," "office fees," or "application support fees," if there is actual document preparation involved, it is likely to be evaluated as illegal.
Of particular note is the establishment of the "double penalty provision" (a system where penalties apply to corporations as well). Previously, only individuals who committed violations were subject to punishment, but after the revision, 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 may be subject to punishment.

JP