For companies employing Specified Skilled Workers (SSW): Having a registered support organization prepare the SSW annual report (periodic notification) without a Gyoseishoshi license violates Article 19 of Japan's Administrative Scrivener Act. Sakura Central Legal Office legally handles both the annual report and the residence status renewal in a single all-in-one package.
The Burden of the Annual Report (Periodic Notification)
Companies that employ Specified Skilled Workers are required to submit a periodic notification (annual report) to the Immigration Services Agency. The volume and complexity of documents required for this notification is comparable to a residence status renewal application — it is by no means a minor administrative task.
Key Documents Required for the Annual Report
| Category | Main Documents |
|---|---|
| Employment status | Terms of employment notification, payslips, employment insurance enrollment proof |
| Support implementation | Life support records, consultation logs, interview records |
| Activity details | Work history, duties performed, transfers or job changes |
| Organization's financial status | Financial statements, tax returns, social insurance payment records |
Compiling all of these documents accurately and on time creates a significant burden on HR and general affairs departments — often disrupting routine operations. For companies that handle support in-house (rather than delegating to a support organization), preparation alone can take several weeks.
The Serious Legal Risk: Article 19 of the Administrative Scrivener Act
A risk that is often overlooked is the legal liability involved.
Article 1-2 of the Administrative Scrivener Act defines the preparation of documents submitted to government agencies as the exclusive work of Gyoseishoshi (administrative scriveners). Article 19 prohibits anyone without a Gyoseishoshi license from performing this work as a business.
The SSW annual report (periodic notification) is submitted to the Immigration Services Agency — a government agency. Accordingly, a registered support organization without a Gyoseishoshi license that prepares these reports as part of its services is in violation of Article 19 of the Administrative Scrivener Act.
"No person other than a Gyoseishoshi or Gyoseishoshi corporation may perform as a business the services set forth in Article 1-2." Violations are punishable by up to one year of imprisonment or a fine of up to ¥1 million (Article 21 of the same Act).
If your company has been relying on a non-licensed support organization, social insurance labor consultant firm, or similar entity to prepare the annual report, that service provider may be operating in violation of the law. If this issue comes to light, the validity of the submitted documents and your company's legal standing may also be affected. We strongly recommend verifying the licensing status of your service provider immediately.
Our All-in-One Package at Sakura Central Legal Office
At Sakura Central Legal Office, a licensed Gyoseishoshi legally handles both the annual report and the residence status renewal in a single engagement.
What the Package Covers
- Annual report (periodic notification): document collection, preparation, and submission — legally handled by a Gyoseishoshi
- SSW residence status renewal application — submitted directly by our Ministry of Justice certified immigration representative
- Pre-submission document checklists and collection support
- Centralized residence status expiry tracking and advance renewal reminders
- Coordination with related organizations (support plan, industry councils, supervision organizations)
Package Comparison
| Sakura Central (licensed Gyoseishoshi) | Non-licensed support organization / SR firm | |
|---|---|---|
| Annual report preparation | ✅ Legal (Gyoseishoshi exclusive work) | ❌ Violates Article 19 of the Act |
| Residence status renewal | ✅ Legal (certified immigration rep.) | ❌ Cannot represent without certification |
| One-stop service | ✅ Single point of contact | △ Multiple vendors often needed |
| HR/admin burden | ✅ Substantially reduced | △ Document gathering still falls on employer |
Client Testimonials
Manufacturing / 3 SSW employees
"Immigration applications are handled legally and correctly, so we no longer worry about residence status expiry dates. Before, our HR team would panic whenever a renewal deadline approached — now we have someone managing the schedule for us."
Food processing / 5 SSW employees
"The annual report preparation was so demanding that it was affecting our day-to-day operations. Delegating everything to Sakura Central resolved all of those issues. The documents are now prepared correctly and our interactions with the immigration office have become much smoother."
Key Takeaways
- The SSW annual report (periodic notification) is a government-submitted document — its preparation is the exclusive work of Gyoseishoshi
- Support organizations without a Gyoseishoshi license preparing these reports violate Article 19 of the Administrative Scrivener Act
- Sakura Central legally handles both the annual report + residence status renewal in a single all-in-one package
- Substantially reduces the HR and administrative burden — we manage deadlines and document submission
- Initial consultation is free. We recommend first verifying your current legal risk
For details and quotes, see our Services page or contact us through our consultation form. Initial consultation is free.
⚖️ Expert Comment — Licensed Gyoseishoshi (Administrative Scrivener)
📋 Practical Background
As the SSW program has grown, many new providers have entered the registered support organization market — often without recognizing that a Gyoseishoshi license is required to prepare the annual report as a business service. Sakura Central holds both a registered support organization designation (through Sakura Training Organization) and a licensed Gyoseishoshi practice, making seamless, fully legal one-stop service possible.
⚠️ Common Misconceptions
"We use a social insurance labor consultant, so we're fine." Social insurance labor consultants (sharoushi) are authorized to handle labor and social insurance documents — but preparing immigration notifications (such as the SSW annual report) for clients falls outside their legally authorized scope. Check the specific license held by your current service provider.
✅ Action Steps
(1) Verify whether your current annual report / residence status renewal provider holds a Gyoseishoshi license. (2) If not, consider switching to a licensed provider promptly. (3) Use our free consultation to assess your current legal risk and discuss a smooth transition.