Swiss Transparency Register: What Companies Need to Know from October 2026

The Transparency Register is based on the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG), which the Federal Councils adopted on September 26, 2025, along with a partial revision of the Money Laundering Act (MLA). The Federal Council has set October 1, 2026, as the effective date.

The aim of the Act is to combat money laundering and terrorist financing and to meet international standards, such as those required by the Financial Action Task Force (FATF). The register is managed by the Federal Office of Justice (FOJ); the electronic reporting platform EasyGov is operated by SECO. A control body at the Federal Department of Finance (FDF) monitors the accuracy, completeness, and timeliness of the information.

The Transparency Register is a new, central, purely electronic federal register (Art. 20 para. 2 TJPG ), in which Swiss companies must report their beneficial owners.

According to the Act, those subject to reporting obligations include, in particular:

• Public limited companies (AG)
• Limited partnerships with share capital
• Limited liability companies (GmbH)
• Cooperatives
• Certain collective investment schemes (e.g., SICAV and SICAF)
• Foreign legal entities with a branch registered in the commercial register in Switzerland, with actual administration in Switzerland, or that own real estate in Switzerland

Excluded from the scope are legal entities whose equity securities are wholly or partly listed on a stock exchange, as well as their subsidiaries held more than 75%, occupational pension schemes, and legal entities where at least 75% of the equity securities are held by public bodies (Art. 3 TJPG). Associations and foundations are not subject to the TJPG from the outset, as they are not listed in Art. 2 TJPG.

No. Unlike the commercial register, the Transparency Register is not publicly accessible. Access is exclusively granted to the authorities exhaustively listed in the Act, such as the Money Laundering Reporting Office and the competent authorities in the area of administrative assistance in tax matters, as well as, for the purpose of fulfilling their due diligence obligations under the MLA, financial intermediaries and certain advisors (Art. 25–27 TJPG). Third parties do not have access to the register.

Affected companies can request confirmation of their registration or an extract from the register at any time (Art. 28 TJPG).

A beneficial owner within the meaning of the TJPG is any natural person who controls a company by:

• directly or indirectly, alone or in concert with third parties, holding at least 25% of the capital or votes in the company, or
• actually controlling the company in another way.

If no person meeting these criteria can be identified, the highest member of the executive body is subsidiarily considered the beneficial owner (Art. 4 para. 2 TJPG ). ). Who this is depends on the company's organization, typically the chairman of the management board or, if none, the chairman of the board of directors.

For shareholders who have already fulfilled their previous obligation to report the beneficial owner to the company, the reporting obligation is deemed fulfilled, provided that the reported persons also qualify as beneficial owners under the TJPG.

The 25% threshold is not the only way to be considered a beneficial owner: anyone who factually controls a company without corresponding capital or voting participation can also be covered by the catch-all provision of "control in another way" (for concrete examples, see FAQ below).

A frequently asked question is whether reporting can only be done via EasyGov. The answer: Generally yes, but not without exception.

EasyGov as the primary reporting channel

Company reports must generally be submitted electronically via the corresponding platform (Art. 22 para. 1 TJPG ). ). EasyGov.swiss, the online portal for businesses, serves as the central federal reporting platform. For companies whose beneficial owners are not already visible in the commercial register, or who wish to report outside of an ongoing commercial register procedure, EasyGov is the only designated reporting channel.

Before the actual report, a one-time registration on EasyGov is required, including a postal authorization process that, according to SECO, can take several weeks. This registration can be prepared now so that the subsequent report can be submitted without delay. According to SECO, the technical infrastructure and the electronic reporting platform have been tested since mid-June 2026 in a pilot project with selected companies; regular operation is planned from the entry into force of the Act on October 1, 2026.

Exception: Reporting via the Cantonal Commercial Register Office

The Act provides for an exception to electronic reporting via EasyGov: according to Art. 11 TJPG, reporting can be submitted by post via the competent cantonal commercial register office as part of an impending commercial register procedure, such as a formation, amendment, articles of association amendment, capital change, or change in the board of directors. A prerequisite for this is that all beneficial owners are already visible in the commercial register.

For all other cases, especially if no commercial register procedure is pending or if the beneficial owners are not identifiable in the commercial register, electronic reporting via EasyGov remains the designated method.

Registration, amendment, deletion, and confirmation in the Transparency Register are generally free of charge. However, costs may arise in connection with reminders, official orders, extracts, or special procedures.

For each beneficial owner, the following information must be recorded and reported:

• First name and surname
• Date of birth
• Nationality
• Residential address and country of residence
• Type and extent of control exercised
• Confirmation of AHV number or, alternatively, a copy of an ID document

All information and verification steps must be documented and retained for ten years after the end of the status as beneficial owner (Art. 8 TJPG). The documentation must be kept in Switzerland and made available to the control authorities upon request.

What the company must specifically retain per beneficial owner

Beyond the mere reporting to the Transparency Register, the company must maintain its own proof documentation for each beneficial owner. In practice, this includes:

1. Reported information: first name, surname, date of birth, nationality, residential address and country of residence, and type and extent of control exercised (e.g., specific percentage of participation or description of control in another way)
2. Proof of identity: confirmation of the AHV number or, if none is available, a copy of a valid identification document (passport, identity card, or foreign national's identity card)
3. Underlying documents proving control: depending on the constellation, e.g., shareholder agreements, articles of association, trust deeds, participation overviews, or evidence of the control chain in the case of indirect participation
4. Documentation of verification steps: how the person was identified as beneficial owner, what evidence was obtained, and with which sources (e.g., commercial register) the information was reconciled
5. Updates and change history: date of the last review or confirmation, as well as all changes to beneficial ownership over time, each with date and reason

1. Prepare for EasyGov registration

Companies can already register on EasyGov to enable subsequent reporting without delay. SECO explicitly recommends that companies or their service providers (agents) register immediately.

2. Identify beneficial owners

The company must check which natural persons meet the 25% threshold or control the company in another way, or who subsidiarily qualifies as a beneficial owner.

3. Request and document information

Shareholders and beneficial owners are legally obliged to provide the company with the required information within one month of the control arising (Art. 13 TJPG); if false or delayed information is provided, they can also be fined. All personal data, as well as the type and extent of control, must then be fully recorded and documented for the ten-year retention period.

4. Submit the report via the appropriate channel

Depending on the situation, the report is submitted electronically via EasyGov or, if a commercial register procedure is pending and all beneficial owners are already visible there, by post via the cantonal commercial register office (Art. 11 TJPG).

5. Ensure subsequent reporting and responsibilities

Changes concerning beneficial owners, such as new shareholders or a new board of directors, must be reported subsequently via the electronic platform within one month of becoming aware of them (Art. 10 TJPG). Changes in participations only need to be reported if relevant thresholds are exceeded or fallen below. Internally, it should also be determined who is responsible for reporting and updating; future commercial register transactions are best planned from the outset together with the transparency report.

Since most Swiss companies are already registered in the commercial register, one of two possible transitional periods applies to them. Which period applies depends on whether the beneficial owners are visible in the commercial register and, for the shorter period, on the legal form and audit obligation (Art. 51 TJPG).

Deadline A – two years' time

If all beneficial owners of the company are already registered as shareholders or bodies in the commercial register, there is time until September 30, 2028, at the latest (Art. 51 para. 2 TJPG ).

).

Deadline B – only a few months' time

The “one-month rule”

The "One-Month Rule"Art. 51(1) TJPG ). Art. 51 para. 1 TJPG

What Changes Compared to Previous Practice?

Previously, non-listed companies had to maintain an internal register of beneficial owners and keep it up to date (Art. 697j–697m CO). These provisions are repealed by the TJPG: identification and documentation are now governed by (Art. 7 and 8 TJPG), reporting by shareholders and members by (Art. 13 TJPG); in addition, beneficial owners must be reported to the central federal register.

The share register is not affected: The obligation of the public limited company to keep a share register (Art. 686 CO), and the corresponding obligation of the GmbH to keep a register of members (Art. 790 CO), remain unchanged. The share register proves shareholder status, the Transparency Register identifies beneficial owners. One does not replace the other. Only the separate register of beneficial owners has been abolished.

• However, only the obligation to continue maintaining the register is repealed, not the obligation to retain existing material. Two different deadlines must be distinguished here:
• Transitional period for the old register: The registers of beneficial owners of AGs and GmbHs maintained until the transition, as well as the associated documents, must be retained until October 1, 2036, i.e., for ten years from the entry into force of the TJPG, for example, for later audits or evidence from the period before the transition. The reason for this continuing obligation: the old data will not be automatically transferred to the new register. Companies cannot rely on the beneficial owners identified under previous law for their TJPG report but must re-identify them independently according to the new provisions of the TJPG, not least because the legal definition of beneficial owner in the TJPG differs from the previous definition under (Art. 8 TJPG). The old register thus remains the only source of evidence for the past before October 1, 2026, and must be archived separately.

New, ongoing retention obligation under the TJPG: For reports to the Transparency Register, a separate, also ten-year retention obligation applies (Art. 8 TJPG). However, this does not begin on a fixed date but only at the end of the status as beneficial owner of the person concerned.

What Happens if the Reporting Obligation is Violated? Sanctions in Detail

The reporting obligation is not a mere formality but is associated with clearly regulated and tangible consequences. The TJPG distinguishes several levels of enforcement. ()

Fines for intentional violation (Art. 43 TJPG)

Anyone who intentionally, whereby even conditional intent is sufficient, violates the reporting or information obligations towards the Transparency Register, fails to disclose required information, or provides false information, will be punished with a fine of up to CHF 500,000 (Art. 43 TJPG). This sanction applies to both the company and shareholders and beneficial owners who fail to comply with their duty to cooperate or do so incorrectly. The same applies to false information provided to the control body.

Primary responsibility lies with the highest member of the company's executive body, typically the chairman of the board of directors or the chairman of the management board. ()

Fines for disregard of official orders (Art. 44 TJPG)

Intentional non-compliance with a legally binding order from the control body, such as a request to correct an incomplete or incorrect report, can be punished with a separate fine of up to CHF 100,000 (Art. 44 TJPG).

The control body and its supervisory powers

The enforcement of the TJPG is monitored by a specially created control body assigned to the Federal Department of Finance (FDF). This control body can object to incomplete or incorrect reports and request companies to correct them.

Registration ex officio

Ex officio registration

For Which Companies is the Transparency Register Relevant?

The reporting obligation generally affects all Swiss public limited companies, limited partnerships with share capital, GmbHs, cooperatives, and certain collective investment schemes, regardless of industry or size and subject to the exceptions under Art. 3 TJPG. Even companies with a single shareholder and simple structures must report their beneficial owners. However, the TJPG does not provide for periodic confirmation reports: after the initial report, the obligation is to report changes within one month of becoming aware of them (Art. 10 TJPG). This makes the new obligation significantly broader than many previous MLA provisions, which primarily concerned financial intermediaries.

Significance for Financial Intermediaries

For financial intermediaries, the Transparency Register has a dual relevance.

On the one hand, like any other company, they are themselves subject to reporting obligations and must record and report their own beneficial owners in a timely manner. ()

On the other hand, financial intermediaries can also query the Transparency Register as part of their own due diligence obligations under the Money Laundering Act (Art. 27 TJPG). This has immediate implications for the existing MLA framework or a financial intermediary's MLA directive: this must be adapted accordingly by October 1, 2026, to adequately take into account the new query and reporting options. (Art. 4, 8b und 8c GwG) (Art. 30 TJPG)

There is no obligation to consult the register: querying is a right, and the financial intermediary's own determination of the beneficial owner according to Art. 4, 8b and 8c MLA remains decisive. If this examination, carried out with the diligence required by the circumstances, reveals no discrepancies, the financial intermediary may rely on the register entry (Art. 23 para. 2 TJPG). However, anyone querying should note that a detected discrepancy can trigger a reporting obligation (Art. 30 TJPG, see Question 7) and that a query provided for in the MLA directive becomes a self-imposed, auditable obligation.

Our Recommendation

Regardless of which transitional period applies in individual cases, we recommend making the entry immediately after the register opens on October 1, 2026, even if formally more time would be available. At the same time, it is advisable to complete the registration process now so that the report can be submitted without delay.

This avoids legal issues related to transitional periods from the outset, especially in the event that a commercial register change is imminent at short notice, which would trigger the shorter one-month period.

In any case, it is less crucial to exhaust one's own deadline than to establish clarity about one's own structure early on: identify beneficial owners, obtain the required information, prepare for EasyGov registration, define internal responsibilities, and plan future commercial register changes from the outset with the "one-month rule" in mind.

The Transparency Register is more than an additional administrative obligation: it represents a fundamental shift towards greater transparency in the fight against money laundering and terrorist financing in Switzerland.

We are happy to support you

The introduction of the Transparency Register brings new, sometimes complex reporting obligations for almost all Swiss companies: from identifying beneficial owners to choosing the right reporting channel, to ongoing subsequent reporting and, for financial intermediaries, adapting the MLA directive.