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

calendar-icon 2026/03/01
What has changed in the revised Administrative Scrivener Law? 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 Law enacted in January 2026, the scope of violations and penalties has been significantly strengthened. The key points of the revised law that registration support organizations should be aware of, common violation patterns in the field, and how to establish a legal compliance system are explained. Before the revision, Article 19 of the Administrative Scrivener Law prohibited non-administrative scriveners from creating documents "for remuneration." However, the interpretation in practice had been 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 labeled as "consulting fees," "administrative fees," or "application support fees," if there is actual document creation 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 could also be penalized. This means that if a staff member of a registration support organization violates the Administrative Scrivener Law, not only the individual staff member but also the organization itself could be subject to punishment.

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