Swiss Transparency Register 2026: New Reporting Obligations for Companies and Financial Intermediaries

Switzerland's new Transparency Register has been in operation since 1 October 2026. With the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG), Switzerland has established a central register recording the individuals who actually control companies.

The new rules affect not only large corporate groups but also numerous Swiss SMEs, holding companies and corporate service providers. What do the companies concerned need to bear in mind now?

1. Who must register in the Transparency Register?

The new Act requires numerous companies governed by Swiss private law, as well as certain foreign legal entities, to identify and report their beneficial owners. These include, in particular:

• Companies limited by shares (AG), limited liability companies (GmbH) and cooperatives

• Investment companies with variable capital (SICAV), investment companies with fixed capital (SICAF), partnerships limited by shares and limited partnerships for collective investment schemes

• Foreign legal entities with a relevant connection to Switzerland, in particular where they have a Swiss branch registered in the Commercial Register, are effectively managed in Switzerland, or own or acquire real estate in Switzerland, subject to the statutory requirements

Swiss foundations and associations are not subject to the reporting obligation under the TJPG. In addition, the Act provides for exemptions, in particular for listed companies and certain subsidiaries.

Beneficial owners are natural persons who ultimately control a company, for example through a direct or indirect holding of at least 25 per cent of the capital or voting rights, or through other forms of control.

Companies must identify these individuals and appropriately verify and document their details.

Important: the Transparency Register is not publicly accessible. Access is granted only to legally authorised bodies, including certain authorities, financial intermediaries and regulated advisors.

2. What information must be reported?

Companies subject to the reporting obligation must, in particular, submit the following information about their beneficial owners:

• Surname, first name and date of birth

• Nationality, municipality of residence and country of residence

• Nature and extent of the control exercised

The initial notification must generally be made within one month of registration in the Commercial Register. Changes to the registered information must be reported within one month of becoming aware of them.

Responsibility for accurate reporting lies with the most senior member of the governing body. The reporting process may be delegated, but the responsibility may not.

3. Transitional deadlines for existing companies

Companies that already existed before 1 October 2026 are subject to staggered transitional deadlines, unless the special two-year deadline applies:

• 31 December 2026: Companies limited by shares subject to an ordinary audit requirement

• 31 January 2027: Other companies subject to an ordinary audit requirement

• 28 February 2027: Companies limited by shares not subject to an ordinary audit requirement

• 31 March 2027: Other companies that do not meet the requirements for a limited audit, and other legal entities (Art. 51 para. 3 let. d TJPG)
  

4. How do registration and reporting work?

Since 1 October 2026, companies subject to the reporting obligation have been able to report their beneficial owners via the federal platform EasyGov.swiss. The following steps are required:

Step 1: Create a personal AGOV account

AGOV is the Swiss authorities' login. Registration is carried out by a natural person: https://www.agov.admin.ch

Step 2: Register with EasyGov and link the company

Register on https://easygov.swiss using your AGOV login and link your personal user account to the company's UID. This triggers a power of attorney process. Validation usually takes a few days. If the company is already connected to EasyGov, a person with the appropriate administration rights can grant you the necessary permissions.

Step 3: Report the beneficial owners

Once access has been successfully activated, select the service ‘Swiss Transparency Register’ on EasyGov and submit the required information. Before doing so, review and document the ownership and control structure as well as the identity of the persons to be reported.

Registration with EasyGov and reporting to the Transparency Register are free of charge. Start setting up access in good time so that the power of attorney verification does not delay your timely notification.

Further information:

• Swiss Transparency Register: https://www.transpareg.admin.ch/de

• Official EasyGov guide: https://www.transpareg.admin.ch/de/ueber-easygov

5. What does the register mean for financial intermediaries?

For financial intermediaries and regulated advisors, the register provides an additional source of information when establishing the identity of beneficial owners.

However, their own AMLA due diligence obligations remain in place. Register information replaces neither risk-based verification nor the required documentation.

Under the statutory conditions, financial intermediaries must also report any discrepancies identified between their own findings and the register information. Owing to the transitional provisions, this obligation only applies six months after the Act's entry into force.