It is only a few days away: on 1 October 2026, the Transparency Act (TJPG) and the revised Anti-Money Laundering Act (AMLA) enter into force. From that day, the Swiss Transparency Register accepts reports, and the transitional periods start running.
There is no need to panic. Most companies have several months. But anyone who does the groundwork now can complete the report in a few minutes instead of searching for documents under time pressure in spring. This checklist takes you through the key points.
Part 1: Transparency Register
1. Determine your deadline
First, clarify by when your company must report. For most SMEs: AG without ordinary audit by 1 March 2027, GmbH by 1 April 2027. If all beneficial owners are already registered in the commercial register, you have two years. All variants are covered in our article Transparency Register Reporting Deadlines.
2. Plan upcoming commercial register changes
Any entry in the commercial register after 1 October shortens the deadline to one month. If a change on the board, a move of the registered office or a capital increase is coming up, plan the Transparency Register report at the same time.
3. Map the ownership structure
Map out who owns the company, all the way down to the natural persons at the end of the chain. For holding structures, this is the most time-consuming step. The rules are explained in our article Who Is a Beneficial Owner?
4. Check for control in another way
Not all control shows up in the share register. Review shareholders’ agreements, fiduciary arrangements, options and loan agreements with say-so rights. Anyone with influence through such instruments may be a beneficial owner, even without holding 25%.
5. Collect details and documents
For each beneficial owner you need, among other things, name, date of birth, nationality and residential address. If the person has a Swiss social security (AHV) number, it is recorded. Otherwise, a copy of the passport or ID card is required. The nature and extent of control must also be documented.
6. Inform shareholders and partners
Shareholders are legally obliged to provide the company with the necessary information. A short letter asking them to confirm the ownership situation creates clarity and also serves as evidence.
7. Don’t rely on the old register
Many companies keep a list of beneficial owners under the Code of Obligations. These provisions are repealed with the new law, and the new definition is broader. Use the old list as a starting point, but check it against the new rules.
8. Register on EasyGov
Reports are filed electronically via the federal EasyGov platform. Registration is already possible today. Having access in advance saves you a step on the key date.
9. Define responsibility and process
The most senior member of the management body is responsible, for an AG usually the chair of the board of directors, for a GmbH the chair of the management. Decide who actually files the report and how later changes, such as a sale of shares, are reported internally. Such changes must be reported within one month.
Part 2: Anti-Money Laundering Act
10. Check whether your business is newly covered
The revised AMLA now covers certain advisory activities: involvement in real estate transactions, setting up and managing companies without operating activities and offering domicile addresses. This affects not only lawyers and fiduciaries but also businesses offering such services on the side. More in our article Revised Anti-Money Laundering Act.
11. Prepare to join an SRO
Anyone covered must file an application to join a self-regulatory organisation by 1 December 2026. Whether this applies to you can be clarified in a few minutes with the self-check at gwgcheck.ch.
12. Expect more questions
Even if you are not covered yourself, you will notice the new rules: banks, fiduciaries and domicile providers must check their clients more closely. Keep IDs, proof of ownership and information on the source of funds ready. This speeds up every account opening and every new mandate.
All information on obligations, deadlines and reporting is available in one place at transparenzregister.ch.
FAQ
What happens if I am not ready on 1 October?
Nothing, as long as you meet your deadline. Most companies have several months. Just make sure that no commercial register change shortens the deadline prematurely.
Does a dormant company also have to report?
Yes. The reporting duty does not depend on whether the company is active. If you no longer need a company, you may want to consider liquidation.
Can I delegate the report to a service provider?
Yes. Responsibility remains with the most senior management body, but the report itself may be delegated, for example to a fiduciary.
Is the Transparency Register public?
No. Only authorities, financial intermediaries and advisors subject to the AMLA have access, and only to the extent they need the information for their legal duties.
Do I have to report every year?
No. There is no annual report. A new report is required as soon as something changes regarding the beneficial owners, and within one month.
Would you rather not work through the checklist alone? SWISS COMPANY AG clarifies your structure, collects the documents and files the report with the Transparency Register. More about the Swiss Transparency Register
This article is for general information only and does not replace legal advice in individual cases.
