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Key Takeaways
- On 1 October 2026, the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG, also referred to as LETA) enters into force together with the revised Anti-Money Laundering Act – the Federal Council decided this on 12 June 2026.
- Most Swiss corporations, limited liability companies and cooperatives are affected, along with certain foreign legal entities connected to Switzerland. New companies generally face a one-month deadline, while existing companies benefit from staggered transition periods.
- A person generally counts as a beneficial owner where they hold at least 25% of the capital or voting rights – or exercise comparable influence in another way, for example through veto rights or the right to appoint board members.
- Trustees resident or administered in Switzerland face separate obligations that apply from day one, with no transition period – even though the trust itself is not entered in the register.
- Intentional violation of the reporting or documentation duties can result in a fine of up to CHF 500,000.
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What is the Transparency Register, and why is Switzerland introducing it now?
The TJPG creates a central, non-public federal register of beneficial owners. It is maintained by the Federal Office of Justice (FOJ), while a control body within the Federal Department of Finance (FDF) reviews the accuracy, completeness and currency of the information. Through the TJPG, Switzerland implements international standards for combating money laundering and terrorist financing. The Federal Council brought the Act and Ordinance into force from 1 October 2026 so their effectiveness can be assessed during the 2027–2028 FATF country evaluation.
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Who actually has to file?
The reporting duty primarily falls on capital companies such as AGs and GmbHs, but also on cooperatives and certain foreign legal entities with a sufficient link to Switzerland. Even companies with a single shareholder and a simple structure must file a report confirming that the data on record is current and correct – there is no exemption from this for simple structures. Filing is done primarily electronically via the EasyGov platform or through the competent commercial register office, and must include, alongside core data, supporting documents such as articles of association, register extracts and proof of ownership.
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Who counts as a beneficial owner?
The general threshold is a holding of at least 25% of the capital or voting rights. Beyond that, a person with a smaller stake can also count as a beneficial owner if they exercise comparable influence in another way – for instance through voting or contractual rights that give decisive influence over company decisions, veto rights over important strategic matters, the right to appoint board members, or dominant influence over financing or strategic direction. This assessment can become complex in multi-layered ownership, family or trust structures, since indirect control and shared influence must also be taken into account.
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What deadlines apply to existing and new companies?
Companies newly entered in the commercial register after commencement generally face a one-month filing deadline. For existing Swiss legal entities, Art. 51 TJPG provides staggered transition rules. Companies with simple structures whose beneficial owners are already fully apparent from the commercial register file at the first relevant register change and no later than within two years. Other companies face deadlines of three, four, five or six months from 1 October 2026, depending on legal form and audit status. Foreign legal entities under Art. 53 TJPG generally have six months. Reported information must then be updated within the statutory periods. The applicable deadline must therefore be determined from the entity’s legal form, audit status and structure.
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What special obligations apply to trustees?
Trustees resident or administered in Switzerland must obtain, verify, document and retain information on the trust’s beneficial owners – the settlor, trustees, protectors, beneficiaries, and any other person with ultimate control. The trust itself is not entered in the register and has no direct filing obligation; however, the relevant information must be kept readily available in Switzerland at all times. Notably, no transitional period applies to trustees – their obligations apply in full from the date the law enters into force. Where a trust holds a qualifying interest in, or controls, a reporting Swiss entity, that entity must additionally report the relevant trust-related information to the register.
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Is the register publicly accessible?
No. The Transparency Register is a central, non-public federal register. Access is limited to certain authorities and, under defined conditions, financial intermediaries acting within their statutory due diligence obligations. Registration, amendment and deletion of an entry, and the issuance of a confirmation of registration, are free of charge; reminders, requests and orders from the register authority or the audit body, as well as the issuance of an extract, are subject to fees.
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What happens in the case of violations?
Anyone who intentionally violates the reporting or documentation duties – for instance through a failure to report, non-disclosure of required information, or false statements – risks a fine of up to CHF 500,000. This can affect both the reporting company itself and shareholders and beneficial owners, who are required to cooperate in the identification and control-chain review by providing the company with the necessary information and supporting documents.
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What should companies and trustees do now?
Four steps deserve priority: first, assessing whether one’s own company, its foreign subsidiaries with a Swiss connection, or administered trusts fall within the scope of the TJPG at all; second, identifying beneficial owners against the 25% threshold or the criteria for comparable influence, particularly in multi-layered ownership or family structures; third, building documentation that clearly evidences the origin and extent of control; and fourth, preparing the electronic filing via EasyGov well ahead of the relevant deadline. Trustees in particular should not wait until entry into force, given the absence of a transitional period.
Register preparations should be aligned with the new AMLA duties for advisers. Foreign legal entities with Swiss real estate should also review their Lex Koller and property-holding structure.
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Frequently Asked Questions
Do companies with just a single shareholder also need to file a report? Yes. Even with the simplest structure involving a single person, a report must be filed confirming that the data is current and correct.
From what level of ownership does someone count as a beneficial owner? Generally from 25% of the capital or voting rights – or from a comparable level of control exercised in another way, such as veto rights or appointment rights.
Does our trust itself need to be entered in the Transparency Register? No. Trusts themselves are not entered in the register. Trustees must, however, obtain and document the relevant information and keep it readily available in Switzerland at all times – with no transitional period.
Is the Transparency Register publicly accessible, as in some EU states? No. It is a non-public register with restricted access limited to certain authorities and, under defined conditions, financial intermediaries.
What does filing with the Transparency Register cost? Initial registration, amendments, deletions and the issuance of a confirmation of registration are free of charge. Reminders, official requests and the issuance of an extract, however, are subject to fees.
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