On 1 October 2026, the Swiss Transparency Register goes live. From that day, companies must report their beneficial owners to the federal government. Existing companies, however, do not all have to do this on day one: the law provides for staggered transitional periods. How much time your company has depends on three questions.
Three questions determine your deadline
1. Are all beneficial owners already registered in the commercial register? That is, as partners or as officers, for example as managing director or board member.
2. What is your company’s legal form? AG or another legal form such as GmbH or cooperative.
3. Is your company subject to an ordinary audit? This mainly concerns larger companies. Most SMEs have a limited audit or have opted out entirely.
All deadlines at a glance
| Situation | Deadline from 1.10.2026 | At the latest by |
|---|---|---|
| All beneficial owners are registered in the commercial register | 2 years | 1 October 2028 |
| AG with ordinary audit | 3 months | 1 January 2027 |
| Other companies with ordinary audit | 4 months | 1 February 2027 |
| AG without ordinary audit | 5 months | 1 March 2027 |
| All other companies and legal entities | 6 months | 1 April 2027 |
For most Swiss SMEs this means: AG by 1 March 2027, GmbH by 1 April 2027, unless the 2-year deadline applies.
The 2-year deadline: who benefits
The longest deadline applies to companies whose beneficial owners are already visible in the commercial register. These companies can also file the report via the cantonal commercial register office.
Typical examples: – A GmbH with two partners each holding 50%. Both are registered as partners in the commercial register. – An AG whose sole shareholder is also its sole board member. He is registered as an officer.
The condition is not met, for example, in an AG with several shareholders who do not sit on the board, or in a GmbH held by a holding company. The holding is registered, but the person behind it is not registered as a partner of the subsidiary.
Caution: the deadline can end earlier
The transitional periods are maximum periods. If your company makes any change in the commercial register after 1 October 2026, for example a change on the board, a new address or a capital increase, the report must be filed within one month of that change, even if the transitional period would have run longer.
Example: A GmbH would have until 1 April 2027. In November 2026 it moves its registered office. The report is then due by December 2026. How a change of seat works is explained in our article Moving Your Registered Office to Another Canton.
New companies and foreign entities
New companies from 1 October 2026: The report is due within one month of registration in the commercial register. If you are forming a company in Switzerland, have the beneficial owner details ready together with the incorporation documents.
Foreign companies: Legal entities under foreign law with a connection to Switzerland, such as a branch, effective management in Switzerland or Swiss real estate, have six months from entry into force for their first report. If the connection to Switzerland is established later, a one-month deadline applies.
After the first report: changes within one month
The first report is not the end of it. If anything changes regarding the beneficial owners, for example through a sale of shares, an inheritance or a new shareholders’ agreement, the company must report this within one month. This requires a clear internal process so that changes actually reach the responsible person.
What happens if deadlines are missed?
A control body at federal level monitors whether the information is complete and correct. Anyone who intentionally fails to report or reports incorrectly risks fines of up to CHF 500,000. In addition, banks and other financial intermediaries can report discrepancies between their records and the register. A missing report can therefore also surface in everyday business, for example when opening an account.
Our tip: don’t wait until the last week
Even if the deadlines seem generous, the groundwork takes time. Shareholdings must be traced to the natural person, IDs collected and agreements reviewed. Anyone registered on the EasyGov platform with their documents ready can report directly from 1 October.
An overview of the deadlines and obligations is available at transparenzregister.ch. Who counts as a beneficial owner is explained in our article Who Is a Beneficial Owner?
FAQ
Can I report before 1 October 2026?
No. The register only accepts reports from entry into force. Registering on EasyGov and preparing the documents is, however, possible beforehand.
My GmbH has only one partner. Which deadline applies?
If the partner is a natural person registered in the commercial register, the 2-year deadline usually applies. What matters is that no other person controls the company in another way, for example through a fiduciary agreement.
Does a change of address count as a commercial register change?
Yes. Any entry in the commercial register after 1 October 2026 triggers the one-month deadline, even a mere change of address.
What if I cannot identify the beneficial owner?
Then the company must report exactly that, with all information available. If nobody reaches the threshold, the most senior member of the management body is reported.
Who in the company is responsible for meeting the deadline?
The most senior member of the management body, usually the chair of the board of directors or of the management. The report itself may be delegated to a service provider.
Would you rather not prepare the report yourself? SWISS COMPANY AG clarifies your ownership 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.
