TJPG · effective Oct 1, 2026
Swiss Transparency Register: What your company now has to report
Oct 1, 2026
500,000+
CHF 500,000
DEADLINE
October 1, 2026 — the reporting and identification obligations apply from this date. The Federal Council set the entry into force on June 12, 2026.
OVERVIEW
What is the Swiss Transparency Register?
The Transparency Register is a central, non-public federal register that records the beneficial owners of legal entities. It is maintained by the Federal Office of Justice (FOJ), and filings are submitted electronically through the federal EasyGov platform.
The goal is to give the competent authorities fast, reliable access to the actual ownership and control structures of companies. In doing so, Switzerland closes existing transparency gaps, strengthens the fight against money laundering and terrorist financing, and implements the international standards of the Financial Action Task Force (FATF).
Important
The register is not public. Access is limited to certain authorities and — under legally defined conditions — to obligated parties such as financial intermediaries. A control body attached to the Federal Department of Finance oversees the completeness and accuracy of the reported data.
LAW
Legal basis: the TJPG and the AMLA revision
The basis is the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG). Parliament adopted it on September 26, 2025, together with a partial revision of the Anti-Money Laundering Act (AMLA / GwG).
Identification duty
TJPG · Art. 7Companies must obtain and keep current the information needed to identify and verify their beneficial owners.
Scope
TJPG · Art. 2 & 3Defines which legal entities must file — in particular corporations such as the AG and GmbH, as well as cooperatives.
Access to the register
TJPG · Art. 26 & 27Sets out conclusively which authorities and persons may access the register data for legally defined tasks.
Entry into force
Effective · Oct 1, 2026The TJPG and the revised AMLA take effect on October 1, 2026. The technical pilot began on June 16, 2026.
WHO IS AFFECTED
Who must file?
The obligations fall on the legal entity itself — acting through its governing bodies (board of directors or management). The following must file, in particular:
- Stock corporations (AG) and partnerships limited by shares
- Limited liability companies (GmbH)
- Cooperatives
- Investment companies with variable or fixed capital (SICAV / SICAF) and limited partnerships for collective investment
- Foreign legal entities with effective management or real estate ownership in Switzerland
- Trustees resident or domiciled in Switzerland
EXEMPTIONS
Who is exempt from the reporting obligation?
Not required to register in the Transparency Register are, among others:
- Foundations and associations
- Listed companies (and companies more than 75% controlled by a listed company)
- Sole proprietorships
- Pension funds and — in principle — insurance companies
Important
An exemption from the direct reporting obligation does not automatically mean no disclosure duties arise. If an exempt entity holds more than 25% in an AG or GmbH, it may still have to be disclosed as that company's beneficial owner.
DEFINITION
Who qualifies as a beneficial owner?
A beneficial owner is the natural person who ultimately controls a company — directly or indirectly. The relevant threshold is generally a holding of 25% of the capital or voting rights. However, anyone who exercises comparable control by other means is also covered. In multi-tiered ownership, family, or trust structures, the entire control chain must therefore be analyzed.
Note — new definition
The TJPG definition of the beneficial owner differs from the previous definition under the Swiss Code of Obligations. Existing filings made under the old law should be reviewed for TJPG compliance.
CONTENT
What information must be reported?
For each beneficial owner, as well as for the company, the following information must be captured, among others:
| Item | Details |
|---|---|
| Identity | Name, date of birth, nationality, and place of residence of the beneficial owner |
| Control | Nature and extent of the control exercised (e.g., size of the holding) |
| Control chain | Representation of the holding where it is held indirectly through several legal entities or trusts |
| Company | Identifying information about the reporting legal entity |
| Evidence | Documentation and supporting records verifying the information (to be retained) |
DEADLINES
Which deadlines apply?
Initial filing
1 month after registrationNew companies have one month from entry in the Commercial Register to report their beneficial owners.
Changes
Within one monthChanges must be reported within one month — provided they cause relevant thresholds to be exceeded or fallen below.
Existing companies
Transition periodsFor companies already in existence, the TJPG provides staggered transition periods for the initial filing.
Financial intermediaries
30 days on a discrepancyIf a financial intermediary identifies a doubtful discrepancy with the register data, it must be reported within 30 days.
RISK
Penalties and consequences
A willful breach of the identification and reporting obligations can be punished with a fine of up to CHF 500,000. There are practical consequences as well:
- Tax authorities gain access to ownership and control structures — discrepancies with tax returns can trigger deeper reviews.
- Although a statutory presumption of accuracy was rejected, a de facto shift in the burden of proof is likely in practice.
- Defects in the ownership structure can delay transactions, financing, and due diligence.
AMLA REVISION
New obligations for advisers
Alongside the TJPG, the AMLA revision broadens the scope of the Anti-Money Laundering Act. Certain advisory activities are now covered — in particular in connection with real estate transactions and with the formation and structuring of legal entities. As a result, anti-money-laundering due diligence obligations will also apply to attorneys and notaries when they act in a structuring capacity.
A two-tier system emerges: primary responsibility for correct register filings lies with the company, while obligated parties under the AMLA must independently fulfill their own due diligence duties.
ROADMAP
How to prepare
1 · Scope assessment
Determine whether your company — or a foreign structure with a Swiss nexus — falls within the scope at all.2 · Map the control chain
Chart the ownership relationships across all tiers and identify the beneficial owners under the TJPG definition.3 · Document & verify
Gather the required evidence, verify it with reasonable care, and store the documentation in an audit-proof manner.4 · File via EasyGov
Register on EasyGov early and submit your filing on time. Keep the information current whenever changes occur.SWISS COMPANY AG handles your Transparency Register filing
Since 1988 we have guided entrepreneurs through company formation, administration, and compliance in Switzerland. We take care of the new reporting obligation for you — accurately, on time, and with clear documentation.
- Review of the reporting obligation (scope assessment)
- Identification of beneficial owners
- Building and documenting the control chain
- Filing via EasyGov
- Ongoing updates when changes occur
- Coordination with the Commercial Register & fiduciary
FAQ
Frequently asked questions about the Transparency Register
Note: This article is provided for general information and does not constitute legal or tax advice. Only the TJPG, its implementing ordinances, and the authorities' current guidance are authoritative. For an assessment of your specific case, we recommend an individual consultation. As of June 2026.
