New transparency requirements for companies will come into force on 1 October 2026. We outline who will be affected, what needs to be reviewed and what companies should prepare now.

On 1 October 2026, the new Federal Act on Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) and the corresponding Ordinance (TJPV) will enter into force.

The new Transparency Register is intended to provide greater transparency regarding the ownership and control structures of companies. It will also give the competent authorities an additional tool to combat money laundering and terrorist financing.

Who is considered a beneficial owner?

A beneficial owner is generally a natural person who ultimately controls a company. This is particularly the case where a person, directly or indirectly:

• holds at least 25% of the company’s capital;
• controls at least 25% of its voting rights; or
• exercises control over the company in another way.

If no beneficial owner can be identified, a member of the company’s highest governing body must be registered under certain circumstances.

Identifying the beneficial owner can be challenging, particularly where ownership interests are held through several companies or where shareholders’ agreements, fiduciary arrangements or other special forms of control are involved.

Which companies are affected?

The reporting obligation applies in particular to:

• public limited companies (AG);
• limited liability companies (GmbH);
• cooperatives;
• certain entities in the area of collective investment schemes; and
• under certain conditions, foreign legal entities with a connection to Switzerland.

Not all legal entities are subject to the TJPG. Associations, foundations, simple partnerships, general partnerships and limited partnerships, for example, are generally outside the scope of the Act. The legislation also provides for further exemptions.

What will companies have to do?

Companies subject to the reporting obligation will be required to:

• identify their beneficial owners;
• verify their identities;
• document the relevant information of the beneficial owners; and
• submit the required information electronically to the Transparency Register.

A simplified reporting procedure applies to straightforward ownership structures, including certain GmbHs and single-owner AGs. In these cases, information already recorded in the Commercial Register may be used.

When is the first report due?

Different transitional periods apply to legal entities that already exist when the new legislation enters into force.

Depending on the circumstances, the initial report will generally have to be submitted within three to six months of the legislation coming into force.

A longer transitional period of two years, until 30 September 2028, may apply where all beneficial owners are already registered in the Commercial Register as shareholders or members of the governing bodies.

Changes occurring during the transitional period must also be reported. If the beneficial owners or relevant information changes, the company must generally submit the updated information within one month of becoming aware of the change.

The same one-month deadline generally applies to changes after the company has been registered in the Transparency Register.

We therefore recommend that companies assess their reporting obligations and applicable deadlines at an early stage.

Is the Transparency Register publicly accessible?

No. The Transparency Register will not be publicly accessible.

Access will be limited to the authorities specified by law, as well as certain financial intermediaries and advisers, insofar as they require access to perform their statutory duties.

What are we doing at the moment?

We are currently testing the reporting process as part of a pilot programme, attending relevant training sessions and monitoring how the new reporting requirements will work in practice, including how information may be submitted via the Commercial Register.

Many of our clients will have until 30 September 2028 to complete their initial registration, provided that no changes to their beneficial owners occur during the transitional period.

While we recommend addressing the new requirements in good time, we believe there is currently value in waiting until the reporting systems are fully operational and the initial technical and procedural issues have been resolved.

During our upcoming annual financial statement meetings, we will discuss the new requirements with our corporate clients and ask whether they would like us to handle the reporting on their behalf.

How we can support you

We would be happy to assist you in assessing:

• whether your company is subject to the TJPG;
• who qualifies as a beneficial owner in your particular circumstances;
• which transitional periods and reporting deadlines apply;
• which information and documents are required; and
• whether you qualify for the simplified reporting procedure.

If you wish, we can also take care of the required registration with the Transparency Register on your behalf.

If you have any questions, would like to complete the registration ahead of the applicable deadline, or are interested in participating in the pilot programme, please feel free to contact us.

+41 41 226 30 51
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