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Switzerland has introduced a central transparency register of beneficial owners, and it went live on 1 October 2026. Most Swiss legal entities, along with certain foreign entities that have a Swiss nexus, will have to report the natural persons who ultimately own or control them. This guide covers who is in scope, what you need to file, the exact deadlines, and what happens if you miss them.
In brief: Switzerland’s Transparency Register went live 1 October 2026. Who must report beneficial owners, the 2027 deadlines, and the penalties, explained simply.
What the Switzerland Transparency Register is
The register is created by the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, known in German as the TJPG. The Swiss Parliament adopted the law, and the Federal Council confirmed the start date and issued the implementing ordinance in June 2026. It forms part of a wider reform of Switzerland’s anti money laundering rules, which also updates the AMLA.
The reason behind the new legislation is external as much as domestic. Switzerland was one of the last major financial centres without a central register of beneficial ownership, and the gap showed up in its FATF country review. Setting up a federal register brings the country closer to the international standard for combatting money laundering and terrorist financing, and gives competent authorities a single place to look.
In practice, the new federal register is a central electronic register run by the Federal Office of Justice under the Federal Department of Justice and Police. Companies file through the EasyGov platform, the same portal many already use for their commercial register entry. Unlike the public commercial register, the transparency register is not open to everyone. Access is limited: authorities that need it get in, and financial intermediaries can consult it only for their own due diligence obligations.
Who must report
The scope is broad. The obligation covers the legal forms that make up most of the Swiss corporate landscape:
- Stock corporations (AG) and limited liability companies (GmbH)
- Cooperatives and, in the relevant cases, limited partnerships
- Investment companies with variable or fixed capital (SICAV and SICAF) and other collective investment vehicles
- Foreign legal entities with a Swiss branch, their effective management in Switzerland, or Swiss real estate
- Swiss based trustees
A number of entities sit outside the regime. Listed companies are exempt, because their ownership is already visible through the stock exchange, as are companies that are at least 75 percent owned by a listed company. Public authorities, associations, foundations and sole proprietorships also fall outside the in scope entities. Holding companies are not exempt as a class: if a holding company is a Swiss corporation, it reports like any other.
The common thread is a Swiss nexus. A foreign legal entity with no branch, no Swiss management and no Swiss property has nothing to file. Add any one of those, and the filing obligations apply.
Who counts as a beneficial owner
A beneficial owner is always a natural person, never a company. Under the Swiss law, it is any individual who, directly or indirectly, alone or acting with others, ultimately controls the entity by holding at least 25 percent of the capital or the voting rights.
Control can also exist without shares. A person is a beneficial owner if control is exercised by other means, such as the power to appoint or remove the board, veto rights over key decisions, or decisive influence through an agreement or a family or fiduciary arrangement. Where no individual meets any of these tests, the entity reports its most senior managing member instead, so the register never sits empty.
Indirect control is traced along the ownership chain. If a person holds enough of an intermediate company that in turn holds a qualifying stake in the Swiss entity, you look through the control chains to the ultimate beneficial owner and report that person. Layered structures are exactly where this gets involved, and where the analysis takes real work.
What you have to report
For each beneficial owner you file their identity: name, date of birth, nationality and residential address, together with the nature and extent of the interest or control. You also confirm the basis, meaning whether the person qualifies through capital, votes, or control by other means. The information has to be kept current, so a later change in ownership triggers an update.
Reporting deadlines
The register opens on 1 October 2026. Existing entities then have a staggered window to file, based on their legal form and whether they are subject to an ordinary audit.
| Entity | Deadline |
| Stock corporations subject to ordinary audit | 1 January 2027 |
| Other entities subject to ordinary audit | 1 February 2027 |
| Stock corporations not subject to ordinary audit | 1 March 2027 |
| Other legal entities, including foreign entities | 1 April 2027 |
| Entities whose beneficial owners are already in the commercial register (simplified confirmation) | 1 October 2028 |
Two timing points are easy to miss. Any new company formed after 1 October 2026 must report within one month of its commercial register entry. And any filing after that date, for example a change of signatory, triggers the same one month deadline to report or update the beneficial owners.
Penalties for getting it wrong
Failing to report, or filing false information, can lead to a fine of up to CHF 500,000.
There is an important limit. Only intentional breaches are punishable. Simple negligence is not, after that idea was dropped from an earlier draft of the law following consultation. Intent does still cover the case where a company seriously suspects its filing may be wrong or incomplete and files anyway. An honest mistake will not land you a fine. Deliberately looking the other way can.
Enforcement sits with the competent authorities, and the register can be consulted by criminal prosecution authorities and tax authorities in the course of their work, alongside the Federal Office of Justice that runs it.
Frequently asked questions
On 1 October 2026. Reporting deadlines for existing companies then run from January to April 2027, depending on the legal form of the entity.
No. Access is limited to authorities and, for defined due diligence purposes, to financial intermediaries. The general public cannot browse it, which is the main difference from the commercial register.
Yes, where there is a Swiss nexus: a Swiss branch, effective management in Switzerland, or Swiss real estate. The deadline for these entities to report is 1 April 2027.
Anyone who ultimately controls at least 25 percent of the capital or voting rights, directly or indirectly, is a beneficial owner. Control exercised by other means also counts, even below 25 percent.
Where no individual meets the ownership or control tests, the entity reports its most senior managing member.
The register is part of the same reform that updates the AMLA. It supports combating money laundering and terrorist financing, and responds to points raised in Switzerland’s FATF country review.
A fine of up to CHF 500,000, but only for intentional breaches. Negligence is not penalised.
How Trustmoore can help
The register is new, the deadlines are close, and working out who really controls an entity is rarely as simple as reading a shareholder list. Layered group structures and nominee arrangements have to be traced through the ownership chain before you can file with confidence.
This is where a boutique approach pays off. At Trustmoore we take the time to understand your structure properly, map the beneficial owners across the chain, and prepare a filing that stands up to scrutiny. You deal with people who know your file, not a ticket number in a queue.
If you have Swiss legal entities, or foreign legal entities with a Swiss connection, now is the time to review your structure and get ready to file. For further information on what the register means for your business, get in touch.
Contact Emma, Emma Holthuizen, Head of Country Switzerland, to talk it through.
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Head of Country Switzerland