Since 1 October 2026, Switzerland has a central register of beneficial owners. Most Swiss companies, and foreign companies with a Swiss branch, Swiss management or Swiss real estate, must now report the natural persons who ultimately own or control them. The first deadline falls on 31 December 2026.
For most groups, the filing itself is the easy part. The real work lies in establishing who the beneficial owners are under the new Swiss criteria, and in documenting how control runs through each layer of the structure. This insight sets out what the register is, who must do what, what happens with the information, and how to prepare.
A central, non-public register run by Bern
The register rests on the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG, also known as LETA) and its implementing ordinance (TJPV). Parliament adopted the Act on 26 September 2025. The Federal Council set its entry into force at 1 October 2026, together with a revision of the Anti-Money Laundering Act.
The Federal Office of Justice keeps the register. A separate control office, attached to the Federal Department of Finance, checks whether the entries are accurate, complete and up to date. Filings are made electronically through the federal platform EasyGov.swiss, and in certain cases through the commercial register.
The aim is to let authorities see quickly who stands behind a Swiss legal entity, to counter money laundering, terrorist financing, corruption and sanctions evasion. The register also brings Switzerland in line with the standards of the Financial Action Task Force (FATF).
The new register replaces the internal list of beneficial owners that Swiss companies kept under the Code of Obligations. The criteria are not identical, so that list cannot simply be copied across. Entering, changing and deleting information is free of charge; extracts, reminders and orders from the authorities carry a fee.
Who must report
Swiss legal entities. The duty applies to companies limited by shares (AG/SA), partnerships limited by shares, limited liability companies (GmbH/Sàrl), cooperatives, SICAVs, SICAFs and limited partnerships for collective investment.
Foreign legal entities with a Swiss link. A foreign company is in scope if it:
- has a branch registered in the Swiss commercial register;
- is effectively managed in Switzerland, which the Federal Office of Justice reads as being taxable in Switzerland on that basis; or
- owns Swiss real estate, or acquires it within the meaning of the Lex Koller.
This means that a Dutch B.V. with a registered Swiss branch must report as well. Since 1 October 2026, a foreign entity can only have a Swiss property purchase entered in the land register once it is registered in the Transparency Register. Foreign entities must also appoint a representative or establish a domicile in Switzerland when they register.
Trustees. Trustees resident in Switzerland have their own duty to identify and record the persons behind the trusts they administer. They do not file with the register.
Exemptions. The register does not apply to listed companies, subsidiaries held for more than 75% by listed companies, entities held for at least 75% by public bodies, and supervised pension institutions. Foundations and associations are not in scope either. That said, where a foundation or association sits in the ownership chain of an in-scope company, special look-through rules determine who the beneficial owners of that company are. Exempt entities cannot register voluntarily.
Who counts as a beneficial owner
A beneficial owner is always a natural person. It is the person who ultimately controls the entity, directly or indirectly, alone or together with others. Control exists in two ways.
- Through ownership: holding at least 25% of the capital or the voting rights. Where the interest runs through an intermediate company, the person must control that intermediate company, which in turn holds at least 25%.
- Through other means: for instance a shareholders' agreement, veto rights, the right to appoint or dismiss a majority of the board, options or convertible loans, trust or fiduciary arrangements, or family ties that give decisive influence.
If no natural person meets these tests, the most senior member of the board or management is reported as the beneficial owner. This fallback does not apply where a beneficial owner exists but cannot be identified or verified. In that case the company must document the steps it took and report everything it does know.
A point for Dutch readers. The Dutch UBO register uses a threshold of more than 25%. The Swiss threshold is at least 25%. A shareholder with exactly 25% is therefore not a UBO in the Netherlands, but is a beneficial owner in Switzerland. A Dutch UBO filing is a useful starting point, but it is not a Swiss analysis.
What is reported, and who does what
For each beneficial owner, the company reports name and first names, date of birth, nationalities, municipality and country of residence, and the nature and extent of control. Control is reported as sole or joint, direct or indirect, and within a band: 25 to 50%, more than 50 to 75%, or more than 75%.
A Swiss social security (AHV) number is not required. The system checks identities against the AHV register. For persons who neither live nor work in Switzerland, the company verifies identity with a copy of a passport, identity card or Swiss residence permit. For intermediate companies in the chain, the company records name, legal form, registered office and identification number. Full details of the control chain are required where control runs through at least two intermediate entities or through a trust.
The duties are split as follows:
- The company identifies its beneficial owners, verifies the information with appropriate care, reports it and keeps it current. Supporting evidence must be kept for ten years after a person ceases to be a beneficial owner.
- The most senior board or management member is responsible for the filing. The work may be delegated in writing to an employee or an outside adviser, but the responsibility stays where it is.
- Shareholders, including foreign holding companies, must give the Swiss company the information on their own beneficial owners, and report changes within one month.
- Beneficial owners must provide their details to the intermediate shareholder or directly to the Swiss company.
Changes must be reported within one month. A change in the size of a stake only needs reporting when it crosses one of the bands. A simplified procedure applies to a GmbH whose quotaholders are all natural persons and are the beneficial owners, and to a one-person AG whose sole shareholder is also its sole board member. In those cases the register takes the data from the commercial register.
Deadlines: the first one is 31 December 2026
Companies incorporated since 1 October 2026 must report within one month of their entry in the commercial register. Entities that already existed on that date have a transitional period, which depends on legal form and audit status.
| Entity existing on 1 October 2026 | Report no later than |
|---|---|
| AG subject to an ordinary audit | 31 December 2026 |
| Other entities subject to an ordinary audit (e.g. GmbH) | 31 January 2027 |
| AG not subject to an ordinary audit | 28 February 2027 |
| Other entities not subject to an ordinary audit, and other legal entities | 31 March 2027 |
| Foreign legal entities with a Swiss link | 31 March 2027 |
| Entities whose beneficial owners all appear in the commercial register as partners or officers | 30 September 2028 |
"Ordinary audit" means the full statutory audit only. A company with a limited audit, or one that has opted out of an audit, falls in the later categories.
Watch the commercial register trigger. Any change to the commercial register entry after 1 October 2026 brings the deadline forward to one month after publication in the Swiss Official Gazette of Commerce. This applies even to unrelated changes, such as a new board member, a change of signatories or a new registered office. A board change published on 9 November gives the company until 9 December to file. Groups planning corporate changes should complete the beneficial owner work first.
What happens with the information
It is not public. Unlike some registers in the EU, there is no access for the general public or for parties claiming a legitimate interest. Access is limited to the control office, the authorities named in the Act, and financial intermediaries and advisers subject to the Anti-Money Laundering Act. The authorities include those dealing with criminal prosecution, sanctions enforcement, public procurement and tax. Each may consult the register only for its statutory tasks, and every consultation is logged. The company itself cannot browse the register; it can order an extract or a confirmation of its entry.
It will be checked. Identities are matched automatically against the AHV register. The control office may review entries and order corrections. Banks and other financial intermediaries will compare the register with their own client files. They must clarify discrepancies with the client and report material discrepancies that remain unresolved. In practice, an inconsistent entry can delay account opening, financing and transactions.
It is enforced. Intentionally breaching the reporting or disclosure duties, or providing false information, is punishable by a fine of up to CHF 500,000. Liability rests with the natural persons responsible. Ignoring a final order of the authority carries a fine of up to CHF 100,000. Serious or repeated non-compliance can lead to suspension of shareholder rights and, ultimately, to dissolution and liquidation of the company.
The revised Anti-Money Laundering Act also brings certain advisers into scope, in particular those involved in company formation, structuring and real estate transactions. Expect Swiss counterparties and advisers to ask more questions about your structure from now on.
Seven steps to take now
- Take stock. List every Swiss entity in your group, and every foreign entity with a Swiss branch, Swiss management or Swiss real estate. Check whether an exemption applies.
- Fix the deadline per entity. Confirm the audit type and check whether any commercial register change is planned that would bring the deadline forward.
- Map the chain. Trace ownership and control up to the natural persons, through every holding company, trust, foundation and nominee. Include shareholders' agreements, options and convertibles.
- Apply the Swiss test. Run the beneficial owner analysis on the Swiss criteria. Do not rely on the old internal list or on a Dutch UBO filing.
- Collect and verify. Request the information from shareholders and beneficial owners in writing, and obtain identity documents for persons who do not live or work in Switzerland.
- Set up access early. Designate the filing person and register on EasyGov.swiss with a personal AGOV login. Where an adviser files, EasyGov sends an authorisation letter to the company's registered address for signature, which takes time.
- File and maintain. File before the deadline, keep the evidence for ten years, and build a one-month reporting step into your corporate housekeeping for every share transfer, board change or change in control.
How we can help
We are happy to assist. We can support you with:
- determining which entities in your structure must report, and by when;
- mapping ownership and control chains, including trusts, foundations and cross-border holding structures;
- the beneficial owner analysis under the Swiss criteria, and its alignment with your Dutch UBO filings;
- drafting the information requests to shareholders and beneficial owners;
- arranging the EasyGov access and authorisations, and coordinating the filing;
- keeping the register current after share transfers, restructurings and transactions.
Would you like to know where your structure stands? Please contact us. We will gladly discuss your situation.
This insight is for general information only and does not constitute legal advice. Specific obligations depend on legal form, audit status and ownership structure.
