The new Swiss Transparency Register – key questions and answers

From 1 October 2026, the new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (hereinafter “TJPG”) will come into force in Switzerland. This will impose new obligations on many Swiss companies. Here is an overview of the key questions and answers.

1. What is the Transparency Register and where did the idea come from?

The Transparency Register shows which natural persons actually stand behind a company or control it – the so-called beneficial owners.

The idea is not a Swiss invention, but part of an international drive to combat money laundering, corruption and anonymous corporate structures. The FATF first established global standards on the transparency of beneficial owners back in 2003.
In 2015, Ukraine became the first country to make such information available in a public register. The UK followed in 2016 with the public ‘People with Significant Control’ Register, making it the first G20 country to have such a register. 

The EU also obliged its member states to set up central registers under the 2015 Anti-Money Laundering Directive. 

Switzerland is following this international trend – albeit with a non-public register.

2. Why is the Transparency Register being introduced in Switzerland (only) now?

Switzerland already had rules in place regarding beneficial owners: public limited companies (AG) and limited liability companies (GmbH) in particular were required to record the relevant details; shareholders and members were subject to reporting obligations. However, there was no central government register. 

During the 2016 FATF country assessment, it was found that there was room for improvement in the identification and verification of beneficial owners. 

A decisive moment came in 2022: the FATF tightened its Recommendation 24 and required authorities to have rapid access to adequate, accurate and up-to-date information on the actual owners of companies. 

Consequently, in October 2022, the Federal Council tasked the FDF with drafting the new regulations. 

The main new feature for Switzerland is therefore the centralised recording and state oversight of this information.

3. When will the new regulations come into force?

The TJPG and the Swiss Transparency Register will come into force on 1 October 2026. 

However, this does not mean that all existing companies must have submitted their returns by that date. Depending on their legal form and audit requirements, existing companies are subject to transition periods of between three and six months.
Companies should therefore review their ownership and control structures in advance and compile the necessary information.

4. Who is required to comply? Which companies are affected?

This applies in particular to public limited companies (AG), limited liability companies (GmbH), limited joint-stock partnerships and cooperatives, as well as SICAVs, SICAFs and limited partnerships for collective investment schemes.
Certain foreign legal entities may also be affected – for example, if they have a registered branch or their place of effective management in Switzerland, or if they hold or acquire Swiss real estate. 
Important: Associations and foundations are not required to report. There are also exceptions, for example for listed companies and certain subsidiaries controlled by them, pension funds and state-controlled enterprises. 

5. What are the obligations?

The company must first establish: Who actually controls our company?
It must identify its beneficial owners and verify their identity and their status as beneficial owners with due diligence.
The results and supporting documents must be documented and kept up to date. Changes must generally be reported within one month of becoming known.
The records must generally be retained for a further ten years after the end of the beneficial ownership.
If, despite investigations, a beneficial owner cannot be identified, the unsuccessful attempts to identify them must also be documented.

6. Which body is responsible for the transparency register?

The Transparency Register is maintained by the registering authority at the Federal Office of Justice (FOJ). This is to be distinguished from the supervisory body at the Federal Department of Finance (FDF). The latter carries out risk-based or random checks to ensure that the information in the register is accurate, complete and up to date, and may order measures to be taken in the event of discrepancies. (efd.admin.ch). Notifications are generally submitted electronically, in particular via EasyGov.

7. What information must be reported?

For each beneficial owner, the following details in particular must be reported: surname and first name, date of birth, nationality(ies), residential address and country of residence.
In addition, a declaration must be provided explaining how and to what extent this person controls the company.
It is relevant, for example, whether control is exercised directly or indirectly, alone or jointly with others, and through shareholdings or by other means.
In the case of shareholdings, a distinction is made in particular between 25–50 per cent, over 50–75 per cent and over 75 per cent.

In the case of more complex structures, further details regarding the chain of control may be required.

8. Who has access to the transparency register?

The Swiss Transparency Register is not public. It cannot therefore be searched by anyone, unlike the Commercial Register. 

Access is granted in particular to the supervisory authority and the authorities specified in the Act, as well as to certain financial intermediaries and advisers subject to the Anti-Money Laundering Act. They may only use the data to the extent necessary to fulfil their statutory duties. Nor can the company concerned simply search the register; however, it may request an extract or confirmation of its own entry.

9. What penalties apply for breaches?

These obligations should be taken seriously: anyone who deliberately fails to make the required notification or to report changes risks a fine of up to CHF 500,000.
Penalties may also be imposed for deliberately false, incomplete or late notifications by shareholders, partners or beneficial owners.
Anyone who deliberately provides false information to the supervisory authority may also be fined up to CHF 500,000. The penalty may therefore be imposed personally on the natural person responsible.

The TJPG merely imposes fines. An entry is made on the criminal record if a conviction is handed down with a fine of more than CHF 5,000.00 (Art. 18(1)(d)(3) of the Criminal Records Act). A custodial sentence may be imposed if the fine is culpably not paid (Art. 106(2) of the Swiss Criminal Code, hereinafter ‘StGB’).

10. Who bears responsibility within the company?

In principle, the most senior member of the governing body is responsible for making the declaration to the Transparency Register. In the case of a public limited company (AG), this will typically be the board of directors; in the case of a private limited company (GmbH), it will be the management. The practical implementation may be delegated to an employee, a trustee, a solicitor or another third party. However, responsibility for ensuring the declaration is made correctly remains with the relevant body.  This is precisely why companies should establish clear internal responsibilities and a process for subsequent changes in good time.

You can find further details, examples and the legal basis in our comprehensive guide to the Swiss Transparency Register.