You own and manage your GmbH yourself. Your AG belongs to an international group. Or your company has several shareholders, each with a small stake. What does your business need to report to the Swiss Transparency Register?
From 1 October 2026, the Legal Entities Transparency Act (LETA) introduces beneficial ownership reporting for companies within its scope. The five examples below explain who to report, what to submit and when to file, so you can recognise your situation and plan the next step.
These are separate, illustrative examples. They assume matching capital and voting rights, independent shareholders and no special control rights, trusts, nominee shareholdings or relevant asset-freezing measures. Examples 1–4 concern companies already in existence before 1 October 2026; example 5 covers a new incorporation.
Check the timing: a change to an existing company’s commercial register entry can bring its filing deadline forward. We explain this below.
1) You own and manage your GmbH
You still need to file, but a simplified registration is available.
Suppose you personally own 100% of your GmbH and are its sole managing director. Both roles are already recorded in the commercial register, you hold the shares for yourself, and nobody else exercises control.
You are the company’s sole beneficial owner. Being entered in the commercial register as shareholder and managing director does not automatically complete the Transparency Register registration.
What to submit: use the simplified procedure to confirm yourself as the beneficial owner through EasyGov. The system obtains information from the commercial register; complete anything missing. Your direct ownership falls in the over 75% band. This procedure assumes the GmbH is not in liquidation, bankruptcy or a debt-restructuring moratorium.
When to file: because the sole beneficial owner is already registered as shareholder and managing director, the transitional period is two years from 1 October 2026. Plan to complete the filing by 30 September 2028, unless an earlier commercial-register change brings it forward.
2) Your AG has both individual and corporate shareholders
In this example, only the majority owner of the 70% corporate shareholder must be reported.
Consider an AG with the following ownership structure. None of the individuals has another interest in the group.
| Shareholder of the Swiss AG | Stake in the AG | Who owns that shareholder |
| An individual | 20% | Holds the shares personally |
| Holding Company B | 10% | Two individuals holding 35% and 65% |
| Holding Company C | 70% | Two individuals holding 70% and 30% |
The person owning 70% of Holding Company C controls that company, which in turn holds 70% of the Swiss AG. That person is therefore an indirect beneficial owner of the Swiss AG.
The other individuals are not reportable on these facts. The direct 20% stake and Holding Company B’s independent 10% stake are below the relevant threshold. The 30% owner of Holding Company C does not have majority control of that intermediary.
What to submit: the company details and the reportable individual’s personal information listed below. Record control exercised alone, indirectly, through participation, in the over 50% to 75% inclusive band. This reflects Holding Company C’s 70% stake in the Swiss AG.
When to file: assume the AG is not subject to an ordinary audit and the reportable individual is not entered in its commercial register as a director or other corporate officer. The transitional period is five months: plan to file by 28 February 2027. If an ordinary audit is mandatory, the period is three months: plan for 31 December 2026. An earlier commercial-register change can accelerate either date.
3) Your AG is wholly owned by a listed company
No initial Transparency Register filing is required while the exemption applies.
Suppose a company with shares listed on a stock exchange owns 100% of your Swiss AG. The Swiss subsidiary is exempt from LETA because it is more than 75% held by a listed company.
What to submit: no initial beneficial-owner filing or separate “no beneficial owner” notification is required under this regime. Keep evidence of the parent’s listing and ownership to support your exemption assessment.
When to file: there is no initial filing deadline while the exemption remains valid. Reassess the position if the parent delists or the ownership changes.
The exemption threshold is more than 75%. A listed parent holding exactly 75% does not give its subsidiary the same exemption. Also check that the listing concerns equity interests; listed bonds alone are insufficient.
4) Your GmbH has five shareholders with 20% each
The company still has to file, even though every shareholder is below 25%.
Assume five individuals each hold 20%, nobody has special or coordinated control, and the company has one managing director who is entered in the commercial register.
After confirming that no individual qualifies through ownership or other control, the GmbH must report its sole managing director as the fallback beneficial owner. This rule identifies the person at the head of management for reporting purposes.
What to submit: the company details, the managing director’s personal information and their function. Identify this as a fallback entry; do not assign an ownership band merely because the person manages the company. The simplified shareholder-confirmation procedure is unavailable here, so a standard filing is required.
When to file: because the only reportable person is already entered in the commercial register as managing director, this example qualifies for the two-year transitional period. Plan to file by 30 September 2028, subject to an earlier commercial-register change.
What if there are four shareholders with 25% each? All four qualify through their direct holdings. The threshold is at least 25%, so exactly 25% counts.
5) You are incorporating an AG with an indirect owner
An indirect owner can be reportable even when their calculated economic interest is below 25%.
A holding company owns 40% of a new Swiss AG. Three unrelated individuals each own the remaining 20%. One person owns 60% of the holding company; another owns 40%.
The 60% owner controls the holding company and, through it, the 40% stake in the Swiss AG. That person must be reported. Multiplying 60% by 40% gives a 24% economic interest, but the reporting test follows control of the intermediary and its stake in the Swiss company.
What to submit: the company details and the majority owner’s personal information. Record control exercised alone, indirectly, through participation, in the 25%–50% inclusive band, reflecting the holding company’s 40% stake. The other individuals are not reportable under these assumptions.
When to file: new companies have one month, without the longer transition available to existing companies. If registration is published in the Swiss Official Gazette of Commerce (SHAB) on 17 November 2026, the filing is due by 17 December 2026.
A commercial register change can shorten your deadline
Before relying on a transitional period, check whether your company is changing its registered office, directors or another commercial-register entry.
For an existing company that has not yet filed, the first commercial-register change after 1 October 2026 triggers a one-month filing period, capped by the company’s applicable transitional deadline.
For example, the GmbH in example 1 changes its registered office, with publication in SHAB on 10 November 2026. Its filing is then due by 10 December 2026, even though it initially qualified for the two-year period.
The transitional dates above are practical filing targets based on the statutory
periods. Always work to the earlier applicable date.
What to prepare for your filing
For a standard filing, have the following ready:
- Company details: name, legal form, UID, registered-office municipality, postcode and country, plus the reporting person’s name, function and email.
- Personal information: each reportable individual’s full name, date of birth, all nationalities, residence municipality, postcode and country.
- Identification: establish whether the individual has a Swiss AHV number. If not, obtain the required passport, identity-card or Swiss foreigner-permit copy for the filing.
- Control information: how the person controls the company and the applicable holding band, or the management function for a fallback entry.
Keep the ownership documents supporting your assessment. In the simple corporate structures in examples 2 and 5, separate intermediary details are not required. Chains with at least two intermediaries, trusts, fiduciary shareholdings or specified asset-freezing measures require additional information.
Filings can be made through EasyGov by an authorised person. Arrange access in advance and retain the registration confirmation. Afterwards, report changes requiring an update within one month of becoming aware of them.
Let IncoSwiss take care of your registration
You do not have to work through the filing alone. IncoSwiss reviews your ownership structure, identifies who needs to be reported and confirms the deadline that applies to your company. We guide you through the information and authorisations required, then prepare and submit the application on your behalf.
Whether you manage your Swiss business locally or from abroad, you have one point of contact throughout the process.
Contact IncoSwiss to arrange your Swiss Transparency Register registration. Send us your company name and a brief outline of its ownership, and we will explain the next steps.
For more background, read our guide to the Swiss Transparency Register.
Information checked on 29 September 2026. Further details are available in the official TranspaReg guidance, the Legal Entities Transparency Act and its implementing ordinance.
