From 1 October 2026, Switzerland will introduce a new federal Transparency Register for the beneficial owners of companies and other legal entities.
The new Federal Act on the Transparency of Legal Persons and the Identification of Beneficial Owners (TJPG) was adopted by the Swiss Parliament on 26 September 2025. The Federal Council confirmed the implementing rules and the entry into force of the new regime on 12 June 2026. The TJPG and the related ordinance will enter into force on 1 October 2026.
Most Swiss AGs and GmbHs, as well as a number of other legal entities, will be required to identify their beneficial owners, verify the relevant information, report it to the Transparency Register and keep that information up to date.
For many companies, the key question will be: which natural person ultimately owns or controls at least 25% of the company, directly or indirectly, or otherwise exercises control over it?
For straightforward ownership structures, the answer may be relatively simple. Companies held through holding companies, trusts or several corporate layers may require a more detailed analysis of the ownership and control chain.
IncoSwiss provides a Transparency Register filing service covering the process from beneficial-owner review and identification through to preparation and submission of the filing.
At a Glance: Swiss Transparency Register 2026
| Question | Short answer |
| When does the new regime start? | 1 October 2026 |
| Who is mainly affected? | Most Swiss AGs, GmbHs, cooperatives and certain other legal entities |
| Who is a beneficial owner? | Generally a natural person ultimately holding or controlling at least 25% of capital or voting rights, or exercising control by other means |
| Does indirect ownership count? | Yes |
| When must a newly incorporated company report? | Within one month of its entry in the Commercial Register |
| Can a Commercial Register change accelerate an existing company’s deadline? | Yes. If the initial Transparency Register filing has not yet been made, the first Commercial Register amendment after 1 October 2026 triggers a one-month filing period |
| Is the register public? | No |
| What happens in case of non-compliance? | Intentional reporting violations can result in fines of up to CHF 500’000; additional enforcement measures are possible for repeated or unremedied breaches |
| Can IncoSwiss file for the company? | Yes, with appropriate authorisation |
| IncoSwiss filing fee | CHF 550 |
The Transparency Register will be maintained by the Federal Office of Justice. A separate Control Authority within the Federal Department of Finance will monitor the accuracy, completeness and currency of information in the register.
What Is the Swiss Transparency Register?
The Swiss Transparency Register is a new federal register containing information about the natural persons who ultimately own or control legal entities subject to the TJPG.
Its purpose is to increase transparency around corporate ownership and strengthen Switzerland’s framework for combating money laundering, terrorist financing and other forms of financial crime, while implementing international transparency standards such as those developed by the Financial Action Task Force (FATF).
Unlike the Swiss Commercial Register, the Transparency Register will not be publicly accessible.
Access is restricted to the Control Authority, authorities specified in the legislation and certain financial intermediaries and advisers who are entitled to consult it for the purposes provided by law. A company cannot simply search the register for other companies, although it can request an extract or confirmation relating to its own entry.
The system is based on self-declaration. Companies subject to the new rules are responsible for identifying and verifying their beneficial owners, making the required notification and keeping the information correct and current.
Which Companies Must Report?
The reporting obligation applies to the majority of Swiss legal entities.
Entities subject to the new rules include:
- Aktiengesellschaften (AG / SA)
- Gesellschaften mit beschränkter Haftung (GmbH / Sàrl)
- partnerships limited by shares
- cooperatives
- SICAVs
- SICAFs
- limited partnerships for collective investment
Certain foreign legal entities are also covered where they have a relevant connection to Switzerland, including where they have a branch registered in the Swiss Commercial Register, have their effective management in Switzerland, or own or acquire certain real estate in Switzerland.
Which Entities Are Exempt From Reporting?
Not every Swiss entity is subject to the new Transparency Register requirements.
Entities generally outside the reporting regime include sole proprietorships, simple partnerships, general partnerships, limited partnerships, associations and foundations.
Certain legal entities are also specifically exempt, including:
- legal entities whose participation rights are wholly or partly listed on a stock exchange;
- subsidiaries held more than 75%, directly or indirectly, by one or more such listed entities;
- supervised pension institutions and certain other supervised occupational pension entities; and
- legal entities in which at least 75% of the participation rights are held directly or indirectly by public bodies.
Whether an exemption applies should nevertheless be considered based on the specific entity and ownership structure.
Who Is Considered a Beneficial Owner?
A beneficial owner must ultimately be a natural person.
A company, holding company or other legal entity cannot itself be the ultimate beneficial owner. Where shares are held through intermediate entities or other structures, the ownership and control chain must therefore be traced through to the relevant natural person or persons.
A natural person generally qualifies as a beneficial owner where they ultimately:
- hold at least 25% of the capital;
- hold at least 25% of the voting rights; or
- exercise control over the company by other means.
Control may be direct or indirect and may also be exercised alone or in coordination with third parties. Contractual or other arrangements can therefore be relevant even where a person’s direct shareholding is below 25%.
Example: Direct Ownership
Assume a Swiss GmbH is owned as follows:
- Shareholder A: 60%
- Shareholder B: 20%
- Shareholder C: 20%
Shareholder A meets the 25% ownership threshold and would generally be identified as a beneficial owner.
Shareholders B and C do not meet the threshold through their individual holdings alone, although any other rights or arrangements giving them control would still need to be considered.
Example: Indirect Ownership
Consider the following structure:
Individual → Holding Company → Swiss AG
The analysis does not stop at the holding company.
The ownership chain must be followed through the intermediate legal entity to determine which natural person ultimately owns or controls the Swiss AG. Official TranspaReg guidance expressly requires indirect control through companies, organisations or trusts to be traced through to the relevant natural person.
IncoSwiss Expert Insight: The Direct Shareholder Is Not Always the Beneficial Owner
For a Swiss company owned directly by one or two individuals, identifying the beneficial owners will often be relatively straightforward.
More work may be required where shares are held through foreign holding companies, several corporate layers, trusts or other arrangements affecting control.
In these cases, simply looking at the shareholder recorded directly in the Swiss company’s corporate documents may not be sufficient.
What If Nobody Owns 25%?
The analysis does not stop simply because no shareholder reaches the 25% threshold.
The company must also determine whether any natural person exercises control by other means, for example through contractual arrangements or other mechanisms giving that person decisive influence over the company.
If no natural person satisfies the ownership or other-control tests, the highest member of the company’s managing body is subsidiarily deemed to be the beneficial owner under the TJPG.
Beneficial-owner identification should therefore not be treated purely as a shareholder-percentage calculation.
What Information Must Be Reported?
Under Art. 9 TJPG, the core information reported to the Transparency Register for each beneficial owner includes:
- name and first name(s);
- date of birth;
- nationality or nationalities;
- municipality and country of residence; and
- information on the nature and extent of the control exercised.
Separately, the company itself must obtain and document additional identification information, including the beneficial owner’s address, and verify both the person’s identity and their status as a beneficial owner with the level of care appropriate to the circumstances. Relevant supporting documents must be obtained where necessary.
The company must keep this information current and ensure that it can be accessed in Switzerland. The relevant information and supporting evidence must generally be retained for ten years after the person ceases to be a beneficial owner.
When Must Companies File?
Newly Incorporated Companies
For companies incorporated after the new regime enters into force, the initial Transparency Register filing must generally be made within one month after the company is entered in the Commercial Register.
Existing Companies
Companies already existing on 1 October 2026 benefit from transitional periods.
The applicable period depends on factors such as the company’s legal form, audit status and whether all beneficial owners are already entered in the Commercial Register as shareholders, members or organs.
Certain qualifying companies whose beneficial owners are already fully reflected in the Commercial Register have a transitional period of up to two years. Other companies are subject to shorter periods ranging generally from three to six months, depending on their circumstances. Foreign legal entities subject to the TJPG generally have a six-month transitional period.
The applicable deadline should therefore be checked for the individual company rather than assuming that every existing AG or GmbH has two years to file.
IncoSwiss Expert Insight: A Commercial Register Change Can Accelerate the Initial Filing Deadline
This is one of the most important practical transitional rules.
For an existing Swiss legal entity that has not yet completed its initial Transparency Register filing, the first amendment to its Commercial Register entry after 1 October 2026 triggers a one-month deadline for the initial Transparency Register filing, subject in any event to the applicable final transitional deadline.
For example, a company that would otherwise benefit from a longer transitional period may need to file earlier if it changes its directors, signatories, registered address or another Commercial Register entry.
Once the initial Transparency Register filing has been completed, however, an unrelated Commercial Register amendment does not automatically create a new beneficial-owner filing obligation. Subsequent Transparency Register updates are required where a fact recorded in the Transparency Register itself changes.
What Are the Consequences of Not Filing?
The TJPG provides for significant sanctions. An intentional violation of the reporting obligations under the TJPG can result in a fine of up to CHF 500’000. Intentionally failing to comply with a final order of the Control Authority, where the relevant penalty warning has been given, can result in a separate fine of up to CHF 100’000.
The Control Authority also has administrative enforcement powers. Where reporting obligations are repeatedly breached or a breach remains unremedied despite repeated requests, it may suspend the participation and economic rights of the relevant shareholder or member.
Where the breaches continue and the circumstances justify it — particularly where the entity appears no longer to have business activity or realisable assets — the Control Authority may ultimately order the dissolution and liquidation of the legal entity.
The highest member of the company’s managing body remains legally responsible for ensuring the required filing is properly made, even where the practical submission has been delegated internally or to an external adviser.
What About New Companies?
For newly incorporated companies, beneficial-owner identification should become part of the incorporation and post-incorporation process from the beginning, since the one-month filing period runs from Commercial Register entry.
IncoSwiss incorporates the Transparency Register requirement into the administration of new Swiss companies where applicable.
How Is the Filing Made?
Transparency Register filings are generally submitted electronically through TranspaReg via EasyGov.swiss.
The person making the filing needs a personal AGOV login and must connect their EasyGov account to the UID of the relevant company. This initiates a validation process which, according to the Federal Office of Justice, generally takes several days.
In certain situations provided by law, the information can instead be transmitted via the competent cantonal Commercial Register. This route is available where a Commercial Register filing is being made and the statutory conditions are satisfied, including that all beneficial owners are already entered in the Commercial Register as shareholders, members or organs.
The highest member of the company’s managing body is legally responsible for the reporting obligation. The task of making the actual submission may nevertheless be delegated to another person within the company or to an authorised third party.
This means that IncoSwiss can make the filing on behalf of a company once the necessary authorisation is in place.
A single authorised person can also be authorised by several companies to make filings on their behalf through EasyGov.
Does the Transparency Register Need to Be Updated?
Yes.The obligation does not end after the initial filing. A company must report a change to a fact recorded in the Transparency Register within one month after it becomes aware of the change.
This can include changes affecting:
- beneficial ownership;
- voting rights;
- indirect ownership structures;
- control arrangements;
- residence or nationality information; or
- the nature or extent of a beneficial owner’s control.
For companies using outsourced corporate administration, beneficial-owner reporting should therefore become part of the normal process whenever relevant ownership or governance changes occur.
How Much Does a Swiss Transparency Register Filing Cost?
It is important to distinguish between the government fee and the cost of professional assistance.
Ordinary registrations, amendments and deletions in the Transparency Register are free of government charge. Confirmations of registration are also free. Certain reminders, formal orders and register extracts may, however, be subject to official fees.
Professional assistance with reviewing the ownership structure, identifying the beneficial owners, coordinating the required authorisation and preparing and submitting the filing is a separate service.
IncoSwiss Transparency Register Filing: CHF 550. The standard process includes:
- reviewing the company’s existing corporate and ownership information;
- determining and confirming the beneficial owner or owners to be reported;
- identifying any missing information required for the filing;
- coordinating the relevant EasyGov / TranspaReg authorisation;
- preparing the required power of attorney;
- coordinating the necessary signatures;
- preparing and submitting the Transparency Register filing; and
- standard follow-up connected with the filing.
Where necessary, a new or amended service agreement will be arranged before IncoSwiss acts on behalf of the company.
For more complex structures, for example where ownership passes through several corporate layers or the beneficial-owner position requires additional analysis, further work may be required. Any additional work outside the standard filing scope would be discussed with the client before it is undertaken.
IncoSwiss Expert Insight: The Filing Itself Is Usually Not the Difficult Part
For a straightforward company, entering the required information into the register should generally be relatively simple.
The more important work happens beforehand: confirming that the ownership information is current, identifying the correct natural persons, reviewing indirect ownership and control structures and making sure that the required information is complete.
This distinction is particularly relevant for international corporate groups, where the direct shareholder of the Swiss company may itself be another legal entity.
What Should Companies Do Before 1 October 2026?
Companies can already prepare for the new regime. A practical approach is to:
- confirm whether the company is subject to the TJPG or qualifies for an exemption;
- review the current shareholder and control structure;
- identify corporate shareholders and indirect ownership chains;
- determine which natural persons ultimately satisfy the beneficial-owner tests;
- verify that the relevant beneficial-owner information is complete and current;
- determine the company’s applicable transitional filing period; and
- prepare the necessary EasyGov and AGOV access and any required third-party authorisation.
The Federal Office of Justice specifically recommends registering with EasyGov in advance because the validation procedure may itself take several days.
Companies planning their first Commercial Register amendment after 1 October 2026 before completing the initial Transparency Register filing should pay particular attention to the accelerated one-month filing rule.
Frequently Asked Questions
When does the Swiss Transparency Register start?
The TJPG and the new Swiss Transparency Register regime enter into force on 1 October 2026.
When must a new Swiss company report its beneficial owners?
A newly incorporated company must generally make the Transparency Register filing within one month of its entry in the Commercial Register.
Does a Swiss GmbH have to report?
Most privately owned Swiss GmbHs are subject to the new reporting rules. Specific exemptions may apply depending on the circumstances.
Does a Swiss AG have to report?
Most privately owned Swiss AGs are covered. Listed companies and qualifying subsidiaries, among others, may be exempt.
Does a Swiss branch of a foreign company have to report?
Foreign legal entities with a branch entered in the Swiss Commercial Register are among the foreign entities covered by the TJPG. Foreign legal entities with effective management in Switzerland or certain Swiss real-estate interests may also be subject to the law.
Do Swiss associations and foundations have to report?
No. Associations and foundations are among the entities listed by the official TranspaReg guidance as not subject to the TJPG reporting regime.
Are sole proprietorships and partnerships subject to the Transparency Register?
Sole proprietorships, simple partnerships, general partnerships and limited partnerships are not subject to the TJPG reporting requirements.
What percentage makes someone a beneficial owner?
A natural person generally qualifies where they ultimately hold at least 25% of the company’s capital or voting rights. A person may also qualify through control exercised by other means.
Is the Swiss Transparency Register public?
No. It is a central, non-public federal register. Access is limited to persons and authorities entitled under the legislation.
What happens if a company does not file?
Intentional breaches of the reporting obligations can result in fines of up to CHF 500’000. Repeated or unremedied reporting failures can also result in administrative measures, including suspension of participation and economic rights and, in qualifying serious cases, dissolution and liquidation of the entity.
Can an existing company's transitional deadline be shortened?
Yes. If an existing Swiss company has not yet made its initial Transparency Register filing, its first Commercial Register amendment after 1 October 2026 triggers a one-month period for the initial filing, subject to the applicable final transitional deadline.
How much does the Transparency Register filing cost?
Ordinary registration in the Transparency Register is free of government charge.
For existing clients, IncoSwiss charges CHF 550 for the standard filing service, including review of the relevant ownership information, beneficial-owner determination, EasyGov / TranspaReg authorisation coordination, power of attorney preparation and submission of the filing.
Can IncoSwiss file the Transparency Register notification on behalf of my company?
Yes. The law allows the practical filing task to be delegated to an authorised third party, although responsibility for proper reporting remains with the highest member of the company’s managing body. IncoSwiss can coordinate the relevant authorisation, review the beneficial-owner information and submit the filing on the company’s behalf.
Need Help With the Swiss Transparency Register?
The new Swiss Transparency Register introduces an additional compliance requirement for many Swiss companies from 1 October 2026.
For companies with straightforward ownership, identifying the beneficial owners may be relatively simple. International or multi-layer ownership structures may require a more detailed review before the filing can be completed correctly.
Contact our team to review your company’s reporting obligation and applicable deadline, or instruct IncoSwiss to handle the filing on your behalf.
