Support organization application workflow to prevent administrative scrivener law violations.
Registration support organizations must operate in a way that does not violate the Administrative Scrivener Law and the Immigration Control Law when supporting foreign nationals in their residency status applications. 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 can pose significant risks if violated.
This article explains the basic points for registration support organizations to lawfully proceed with residency status procedures, taking into account the Administrative Scrivener Law amendment that will be enforced from January 1, 8th year of Reiwa.
**Administrative Scrivener Law Basics and Amendment Contents**
Current Law:
- Only administrative scriveners can receive compensation for creating documents submitted to government offices.
Amendment (Enforced from January 1, 8th year of Reiwa):
- The phrase "receiving compensation for accepting the request of others, regardless of the pretext" is added.
- This makes it potentially illegal to provide paid document creation under any pretext such as "consulting fees" or "administrative fees."
**Immigration Control Law Basics: Entities that can act as intermediaries for applications**
- Only administrative scriveners with the qualification to act as intermediaries or approved institution employees can submit residency status applications on behalf of individuals.
- If a registration support organization has approval, intermediary services by employees are lawful, but creating documents for compensation would violate the Administrative Scrivener Law.
- It is crucial to always differentiate "who creates and who submits" the 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 "administrative fees."
- Despite the pretext, creating documents for submission to immigration authorities is illegal after the Reiwa 8th year amendment.
2. Cases including application agency in a "full-service package":
- Contracting for document creation and submission services for residency status under names like "foreign employee recruitment support package" or "registration support full service."
- As part of the services fall under the exclusive business of administrative scriveners, the entire package poses a risk.
**RakuVisa Mechanism: Design to Avoid Administrative Scrivener Law 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 submission to immigration authorities are generated by administrative scriveners through the system during intermediary services.
- The phase where users create application forms does not exist, avoiding the risk of violating the Administrative Scrivener Law.
Furthermore, through immigration API integration:
- Always automatically updated to the latest format.
- 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 amendment to the Administrative Scrivener Law.
**Conclusion: Understand the Amended Administrative Scrivener Law Correctly and Operate Lawfully**
- The amendment to the Administrative Scrivener Law (enforced in the 8th year of Reiwa) makes paid document creation under names like "consulting fees" illegal.
- Registration support organizations need to clearly separate "support services" and "application services" to avoid risks.
- With a design of user input + administrative scrivener intermediary, RakuVisa remains usable with confidence even after the law 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 Law and the Administrative Scrivener Law, prioritize compliance, and establish a safe support flow for business continuity.

JP