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

What has changed with the amendment of the Administrative Scrivener Act With the expansion of the Specified Skilled Worker System, the number of application cases handled by registration support organizations is increasing year by year. Amidst the increasing workload, many may feel uncertain about whether their application workflow is legally sound and where the violation of the Administrative Scrivener Act begins. The amendment to the Administrative Scrivener Act, which came into effect in January 2026, significantly strengthened the scope of violations and penalties. This article explains the key points of the amended 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 amendment, Article 19 of the Administrative Scrivener Act prohibited individuals who are not administrative scriveners from engaging in document preparation "for remuneration." However, the scope of "remuneration" was ambiguous, leading to the interpretation that one could avoid violations by changing the name. Point: The amended law added the phrase "regardless of the name" to Article 19, making it more likely that even if the document preparation is under a different name such as "consulting fees," "administrative fees," or "application support fees," it may be considered illegal if the actual document preparation is involved. Of particular note is the establishment of the "both penalty provision" (a system where penalties apply to corporations as well). Previously, only individuals who committed violations were subject to punishment, but after the amendment, corporations themselves could also be penalized. 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 could 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 seemed problem-free in the past, the amended law now clearly evaluates previously gray areas as violations. Establishing a Compliance System in Three Points: Point 1: Establish a system where document preparation is entrusted to administrative scriveners Point 2: Clearly distinguish between different types of remuneration Point 3: Record and document the workflow RakuVisa: Realizing a Compliance System with Three Points: Point 1: Establishing a system where document preparation is entrusted to administrative scriveners Point 2: Clearly distinguish between different types of remuneration Point 3: Record and document the workflow Conclusion: With the enforcement of the amended Administrative Scrivener Act, the compliance risks for registration support organizations in the field of residence status application have increased significantly. It is important to establish a compliant workflow by entrusting document preparation to administrative scriveners, clearly distinguishing between remuneration, and maintaining a record of the workflow. Establishing a legal processing system in collaboration with administrative scriveners is the foundation for the continued operation and trust of registration support organizations.