Urgent Alert for Registered Support Organizations: Preparing for the Amended Administrative Scrivener Act

Voice Explanation

To all registered support organizations,

Effective January 1, 2026.Revised Administrative Scrivener Lawof specific skills byPreparation of documents for application for status of residence for remunerationbut regardless of the name of theClearly illegalThe first two are the following.

• ⚠️ Risk: If the cost of documentation is included in the support contract fee, etc., it is considered an illegal act,Cancellation of registration and penaltiesThe risk of a "double penalty" arises (with the development of a double penalty provision).
• ✅ Required response:
  1. Complete withdrawal from paperwork: With or without compensation, you should withdraw from the practice of preparing documents for immigration submission.
  2. Review of fee structure and contractsStatements such as: "The support fee includes application preparation.deletionPlease do so.
  3. Collaboration with Gyoseishoshi LawyerImmigration application services to ensure complianceOutsourcing and partnership with administrative scrivenersPlease urgently establish a system to
     
     

Without hesitation, he collaborated with our administrative law firm!

 Specific Skills Why Registered Support Agencies should work more closely with us

We understand that all registered support organizations (hereafter referred to as "support organizations") responsible for the smooth operation of the Specified Skill System are making efforts to stably accept foreign human resources on a daily basis.

However, the new law that will come into effect on January 1, 2026Revised Administrative Scrivener Lawwill have an extremely significant impact on the business operations of support organizations. This amendment to the law clarifies that the act of preparing documents for application for status of residence, which has been considered a "gray zone," is nowillegaland the risk to the survival of the corporation becomes apparent.

In order to continue accepting foreign personnel, cooperation with administrative scriveners is "desirable" toessentialThe new system will turn into a "new" system.

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1. why is collaboration essential? Stricter Exclusive Businesses under the Revised Law

1-1. monopoly of document preparation is strictly enforced by "compensation".

The revised Gyoseishoshi Law clearly prohibits persons who are not qualified as Gyoseishoshi Lawyers from preparing documents to be submitted to public offices (especially residence status application documents) "for remuneration under any name whatsoever".

This is a very important warning for supporting institutions.

• Risks to date: The support organization is from a foreigner with specific skills."Outsourced support costs."The company receives compensation for this service.If this remuneration is considered to include compensation for the preparation of application documents, it is in effect unqualified preparation of documents for a fee, and thus a risk of violating the Administrative Scrivener Law.There was a
• Risks after revision: After the amendment, the receipt of money that is regarded as compensation for the preparation of documents, regardless of the name of the compensation, such as "consulting fee," "administrative fee," "application support fee," etc., is clearly subject to the prohibition.This will be the case. As long as a support organization receives a support consignment fee, preparing residence status application documents for a specified skilled foreigner is in high violation of this provision.

👉 Support organizations are required to completely withdraw from the business of "preparing" residence status application documents in the future.

1-2. beware of "additions and deletions" and "double penalties

In addition to the act of creating a document from scratch, "additions and corrections" that change the substantive content of a previously prepared document are also covered by the exclusive services.

• Any act of modifying or changing the contents of the application documents received from companies or foreign nationals by making practical alterations beyond a formal check could be illegal.There areFinal preparation, verification, and responsibility for the documents is the responsibility of the administrative agent.It is necessary to
• In addition, the revised law provides"Double Penalty."will be maintained. This is when an individual staff member of a support organization engages in illegal documentation practices,Not only its staff, but also the corporation itself of the support organization is subject to punishment.This means that This is the most important risk to avoid, as it directly leads to cancellation of registration and threatens business continuity.

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Specific examples of cooperation with administrative scriveners in the specified skills system

In the specific skills system,Support organizations concentrate on "livelihood supportand compliance with laws and regulations is required.Entrust the "application work" to an administrative scrivener.The safest and most reliable compliance measure is to

Operations requiring collaboration	Role of support organizations (dedicated to livelihood support)	Role of Administrative Scrivener (Exclusive Services)
Application for Certificate of Eligibility	Assistance in gathering necessary information from foreign nationals and companies	Preparation of application forms and submission to the Immigration Bureau (application agency)
Application for Change of Status of Residence	Formulation and implementation of the revised livelihood support plan	Preparation and submission of revised applications to the Immigration Bureau (application agency)
Preparation of various notification documents	Identify information that needs to be reported (e.g., change of place of residence, etc.)	Preparation of notification documents and submission to the Immigration Bureau (application agency)

Thus, for the purpose of ensuring legal compliance (compliance) in the application process in order to continue the stable acceptance of foreign personnel and protect the continuity of your company's business,Establishing a system to leverage the expertise and qualifications of administrative scriveners is "essential.".

The law changes are coming into effect very soon. Review your contracts and workflow now, establish a partnership with an administrative scrivener, and make sure your staff is well informed.

First, please feel free to contact our office!