The introduction of the Swiss Transparency Register will enter into force on 1 October 2026. The new requirements will affect both Swiss legal entities and foreign entities with a connection to Switzerland, as well as their owners. As public awareness of these upcoming requirements remains limited, many affected parties may not yet be aware of the new obligations and the relatively short implementation deadlines.
Below you will find further information on the key provisions of the Swiss Transparency Register and the associated compliance requirements. Our team would be pleased to support you in assessing your obligations and ensuring timely compliance.
What is it about?
In the fall of 2025, the Swiss Parliament passed the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) in response to international requirements, particularly those of the FATF. The corresponding ordinance (TJPV) was adopted on 12 June 2026. The new provisions will take effect on 1 October 2026.
The new law provides for the establishment of a centralised, digitally managed transparency register in Switzerland in which the beneficial owners of certain legal entities are recorded. Although the register is not public, it is accessible to a wide range of Swiss authorities and other authorised parties. The regulations are intended to increase transparency of ownership and control structures and to enhance the effectiveness of anti-money laundering efforts.
The reporting obligation applies primarily to legal entities under Swiss law as well as investment companies for collective investment schemes; however, foreign legal entities may also be subject to the reporting obligation if they i) have a branch (registered in the Swiss Commercial Register) in Switzerland, ii) are effectively managed in Switzerland, or iii) own one or more properties in Switzerland.
However, listed companies and their subsidiaries in which they hold an ownership interest of more than 75%, as well as partnerships, foundations and associations, are exempt from the reporting requirement.
Details regarding the content and scope of the filing, the reporting deadlines and the support available from Avanta can be found in our factsheet.
Who is affected?
The reporting requirement under TJPG applies to:
- Legal entities under Swiss law (public limited companies (AG), limited liability companies (GmbH), partnerships limited by shares (KmAG) and cooperatives); as well as
- Investment companies for collective investments (SICAVs, SICAFs and limited partnerships for collective investment schemes (KmGK)).
Foreign legal entities are also required to report if they have a connection to Switzerland, namely through ownership of real estate in Switzerland, a registered branch in Switzerland or an effective place of management in Switzerland.
Exempt from the reporting obligation are, in particular, listed companies and their subsidiaries in which they hold an ownership interest of more than 75%, as well as foundations, associations and partnerships.
Who is the beneficial owner?
The beneficial owner is defined as any natural person who effectively owns and ultimately controls an entity. Such control may be exercised directly or indirectly, alone or in concert with third parties, through ownership interests and/or voting rights, or by any other means. An entity may have more than one beneficial owner.
What action is required?
If, under the provisions of the TJPG and the TJPV, you are subject to the obligations of the Swiss Transparency Register and are therefore required to report the controlling owner(s) to the Transparency Register, the following steps must be taken:
- Identify its controlling owner;
- Verify their identity and the nature and extent of their control;
- Submit this information electronically to the Transparency Register.
Failure to comply with the reporting obligations constitutes a criminal offence. In cases of intentional non-compliance, fines of up to CHF 500,000 may be imposed.
How can Avanta assist you?
Implementing the new Transparency Register requirements may require substantial analysis, depending on the ownership and control structure. We would be pleased to assist you with all the necessary steps to comply with the new legal requirements.
Our services include the following in particular:
- Assessing whether you are affected and subject to the reporting obligation;
- Identifying the controlling person(s), including the nature and extent of their control;
- Determining the deadline for filing with the Transparency Register;
- Filing with the Transparency Register;
- Providing ongoing register maintenance;
- Assistance with enquiries from authorities and future changes
- Assistance with any additional tax declaration requirements
We would be pleased to review your individual situation and propose an approach tailored to your needs.
How should you proceed?
If you have any questions or require assistance in implementing the new requirements, your Avanta contacts will be happy to assist you at tjpg@avanta.ch or +41 58 255 73 00.
