Application Workflow to Avoid Administrative Scrivener Act Violations by Registered Support Organizations

What Changed Under the Amended Administrative Scrivener Act

With the expansion of the Specified Skilled Worker system, the number of applications handled by Registered Support Organizations has been increasing year by year. As workloads grow, many organizations may be wondering whether their internal application workflows are legally compliant and where the line is drawn for violations of the Administrative Scrivener Act.

The amended Administrative Scrivener Act, which came into force in January 2026, significantly strengthened the scope of violations and penalties. This article explains the key points of the amended law that Registered Support Organizations should understand, common violation patterns that can occur in practice, and how to build a lawful compliance framework.

Before the amendment, Article 19 of the Administrative Scrivener Act prohibited non-administrative scriveners from preparing documents “for remuneration.” However, because the scope of “remuneration” was unclear, an interpretation had spread in practice that violations could be avoided by changing the fee label.

Another important point is the introduction of dual liability provisions, under which penalties may also apply to corporations. Previously, only the individual who committed the violation was subject to penalties, but after the amendment, the corporation itself may also be penalized. In other words, if a staff member of a Registered Support Organization violates the Administrative Scrivener Act, not only the individual staff member but also the Registered Support Organization as a corporation may become subject to penalties.

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Three Common Violation Patterns at Registered Support Organizations

After the amended law came into force, the following types of workflows may carry legal risks.

Pattern 1: Including Document Preparation Fees in Support Fees

This refers to cases where the support fees received by a Registered Support Organization from an affiliated organization, such as an accepting company, substantially include consideration for preparing documents related to residence status applications. Under the amended law, document preparation for remuneration is subject to regulation regardless of the fee label, so if the substance of the support fee includes document preparation, there is a risk that it may be judged as a violation.

Pattern 2: Preparing Application Documents Under the Label of “Consulting”

This refers to cases where services are offered under names such as “application consulting” or “application support,” while in reality the organization prepares residence status application documents. Regardless of the service name, if the substance of the work is document preparation, it is likely to be considered a potential violation of Article 19 of the Administrative Scrivener Act.

Pattern 3: Providing Services as an All-In-One Full-Service Package

This refers to cases where services are offered as an integrated package covering everything from accepting foreign nationals to residence status applications and daily life support, and the package includes document preparation work. Even if remuneration is received for the package as a whole, the same risk arises if the package includes document preparation.

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Three Key Points for Building a Compliance Framework

Point 1: Establish a Framework for Entrusting Document Preparation to Administrative Scriveners

The most reliable measure is to establish a workflow in which document preparation related to residence status applications is entrusted to administrative scriveners. The role of the Registered Support Organization should be limited to collecting and providing factual information about the foreign national and the affiliated organization, while the administrative scrivener handles document preparation and application submission. Clearly defining this division of roles forms the foundation of compliance.

Point 2: Clearly Separate Remuneration Categories

It is important to clearly separate the support fees of the Registered Support Organization and the document preparation fees paid to the administrative scrivener on invoices and receipts. If remuneration is mixed together, there is a risk that the support fee may be assessed as including consideration for document preparation.

Point 3: Record and Preserve Evidence of the Workflow

It is also important to keep records showing “who performed which scope of work.” By preserving evidence of the process in which the administrative scrivener interviews the applicant, confirms the applicant’s intent, and prepares documents based on professional judgment, an organization can objectively demonstrate that its workflow is lawful.

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Implementing a Compliance Framework with RakuVisa

RakuVisa is a residence status application platform that incorporates the above compliance requirements into its system design. It implements an appropriate division of roles between Registered Support Organizations and administrative scriveners as a built-in mechanism.

Specifically, automatic document generation and API-based application submission can only be performed through an administrative scrivener account. The editing authority of Registered Support Organizations is limited to factual information about foreign nationals, affiliated organizations, and the Registered Support Organization itself. This structurally eliminates the risk of a Registered Support Organization preparing documents.

RakuVisa also includes a feature that automatically records and stores web interviews between administrative scriveners and applicants, preserving evidence that the administrative scrivener performed the work based on independent judgment. The API application button is not activated unless the applicant’s consent is confirmed through online signature and eKYC identity verification, together with the interview.

In addition, invoices and receipts clearly separate administrative scrivener fees and system usage fees, helping avoid the risk of mixed remuneration.

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Summary

With the enforcement of the amended Administrative Scrivener Act, compliance risks for Registered Support Organizations involved in residence status application work have become greater than ever. Document preparation for remuneration is now regulated “regardless of the name or form thereof,” and dual liability provisions now allow penalties to apply to corporations as well.

To build a lawful operational framework, it is important to entrust document preparation to administrative scriveners, clearly separate remuneration, and preserve evidence of the workflow. Establishing a system for lawful processing in collaboration with administrative scriveners forms the foundation for business continuity and trust for Registered Support Organizations.

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