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Swiss transparency register: a practical guide

Swiss transparency register: a practical guide

Since 1 October 2026, companies limited by shares (AG/SA), limited liability companies (GmbH/Sàrl) and cooperatives must report to the Swiss Confederation the people who control them. Who to report, by when, how to go about it and what happens next: here is what you need to know to comply.


What the law changes

The Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LTPM in French, TJPG in German) came into force on 1 October 2026. It creates the transparency register, kept by the Swiss Confederation.

Every company concerned must report its beneficial owners there, that is, the people who ultimately control it, and keep this information up to date.

The register is not public. Only the control authority, the authorities designated by law, financial intermediaries such as banks, and certain advisers can consult it.


Which companies are concerned

The following must report:

  • companies limited by shares (AG/SA) and partnerships limited by shares;

  • limited liability companies (GmbH/Sàrl);

  • cooperatives;

  • SICAVs, SICAFs and limited partnerships for collective investment;

  • foreign companies with a branch entered in the commercial register, with their effective management in Switzerland, or with real estate in Switzerland.

Not concerned: listed companies and their subsidiaries held at more than 75 %, pension funds and other pension institutions, and companies held at least 75 % by public bodies.


Who must be reported: the 25 % threshold

You must report every natural person who controls the company:

  • they hold at least 25 % of the capital or votes, alone or together with others, directly or indirectly, for example through a company they control;

  • or they control the company in another way, for example through a shareholders' agreement that lets them appoint more than half of the board of directors or block decisions on strategy, budget or financing.

If nobody meets these conditions, you report the most senior manager: the chair of the executive management or, if there is no separate executive management, the chair of the board of directors or of the administration. If this role is held jointly by several people, all of them are reported.


The information to provide

For each person reported, you must give:

  • surname, first name and date of birth;

  • nationality or nationalities;

  • municipality, postcode and country of residence;

  • the AHV number (the Swiss social security number) or, failing that, a copy of the passport, identity card or residence permit;

  • how the person controls the company: alone or with others, directly or indirectly, through a holding or in another way;

  • for a holding, its band: 25 to 50 %, over 50 to 75 % or over 75 %.

If you report the most senior manager, you must also give their position.


Deadlines: one month after an entry in the commercial register

This is the key point. A new company entered in the commercial register since 1 October 2026 has one month after its registration to report.

A company that was already registered before that date must report by the following dates at the latest:

  • AG/SA subject to ordinary audit: 31 December 2026;

  • GmbH/Sàrl, cooperative or other company subject to ordinary audit: 31 January 2027;

  • AG/SA not subject to ordinary audit: 28 February 2027;

  • GmbH/Sàrl, cooperative or other company not subject to ordinary audit: 31 March 2027;

  • foreign company: 31 March 2027;

  • if all persons to be reported are entered in the commercial register as partners or officers, for example the partners of a GmbH/Sàrl: 30 September 2028.

Important: if a Swiss company has a change entered in the commercial register before these dates, for example a new address, director or managing officer, or a change of capital, it has one month after this first change is entered. The earlier date applies.

These dates follow from the periods set by law: 3 to 6 months, or 2 years, from 1 October 2026.


How to report on EasyGov

Reports are made online on EasyGov, the virtual counter of the Swiss authorities. Reporting is free, as are changes and deletion. Only reminders, formal notices, decisions and extracts are charged.

  1. Create an AGOV account, the online login of the Swiss authorities.

  2. Register on EasyGov and request access to your company. If nobody is authorised for your company yet, EasyGov sends a power of attorney form by post to the company's address. It must be signed in line with the signing rights entered in the commercial register, then returned.

  3. Report your beneficial owners to the transparency register.

The steps are described in the EasyGov InfoCenter. As the power of attorney form comes by post, it is best to start early.

A third party, for example a fiduciary, can also make the report. If the company is not yet registered on EasyGov, the third party requests the rights for the company and EasyGov sends the power of attorney form to the registered office. If the company is already registered, a person with full access can invite the third party. In every case, the most senior manager remains responsible for the report, even if they delegate it.


Simplified reporting for some GmbH/Sàrl and AG/SA

In two cases, the company only confirms who its beneficial owners are, without further information:

  • a GmbH/Sàrl whose partners are all natural persons, whose beneficial owners are all partners, and which is controlled only through its capital shares;

  • an AG/SA whose sole shareholder is a natural person who is also its only beneficial owner and is entered in the commercial register as the sole member of the board of directors.

These two cases do not apply to a company in liquidation, bankruptcy or composition proceedings.


What about the commercial register?

For now, the report cannot yet be made through the commercial register when a new company is registered: it is made on EasyGov. According to the Federal Office of Justice, this route will open later; the commercial register offices of Basel-Stadt and Zug mention 2027.

The law already provides for this route: the report can then be filed together with an application to the commercial register, in a separate document. This will only be possible if all persons to be reported are entered in the commercial register as partners or officers. We will keep you informed.


After the report: keeping the information up to date

Reporting is not a one-off. Every change must be reported within one month: a new person, a holding that crosses the 25, 50 or 75 % threshold, a change of residence. A holding that changes without crossing a threshold does not need to be reported.

A shareholder or partner whose holding allows control of the company must tell the company who the beneficial owner is within one month, and then report every change within the same period. The beneficial owner in turn informs that shareholder or partner, or the company directly if they control it in another way or through several companies or persons.

The company keeps this information up to date and accessible at all times in Switzerland. It retains the information and supporting documents for 10 years after a person stops being a beneficial owner.


What the law provides for breaches

A fine of up to CHF 500'000.- applies to anyone who intentionally breaches a reporting obligation or gives false information to the control authority. A fine of up to CHF 100'000.- applies to anyone who intentionally fails to comply with a decision of the authority.

If reporting obligations are breached repeatedly, or a failure is not corrected despite repeated formal notices, the control authority can suspend the rights of the shareholder or partner concerned. It can also dissolve the company where this is justified, in particular if the company clearly has no remaining activity or realisable assets.


Frequently asked questions

Is the transparency register public?

No. Only the control authority, the authorities designated by law, financial intermediaries and certain advisers can consult it.

Is reporting free?

Yes. Reporting, changes and deletion are free. Only reminders, formal notices and decisions are charged, based on the time spent, as well as extracts at CHF 40.- each.

My company was entered in the commercial register on 20 October 2026. What is my deadline?

One month after registration, so by 20 November 2026 at the latest.

My GmbH/Sàrl has existed for several years and has two partners with 50 % each. What do I need to do?

Both partners are its beneficial owners. If they are natural persons and nobody else controls the company, simplified reporting is possible. As they are entered in the commercial register, the company has until 30 September 2028, unless it has a change entered before then: it then has one month.

Nobody reaches 25 %. Do I still need to report?

Yes. If nobody reaches 25 %, alone or with others, and nobody controls the company in another way, you report the most senior manager, with their position.

Can my fiduciary make the report?

Yes. Your fiduciary can report on EasyGov with a power of attorney signed in line with the signing rights entered in the commercial register. The most senior manager remains responsible for the report.


Conclusion

The transparency register concerns most Swiss companies, but the report itself is free and made online. The key point is the deadline: one month after the first entry in the commercial register made since 1 October 2026, whether for a new company or a change. As access to EasyGov involves a form sent by post, it is best to start early.

Setting up or changing your company? Do it online with NewCo: form your GmbH/Sàrl or your AG/SA, or update your commercial register entry. Questions about the transparency register? Call us on 058 595 99 99 or write to [email protected].


Sources

- Federal Act on the Transparency of Legal Entities (TJPG), German text
- Federal Act on the Transparency of Legal Entities (LTPM), French text
- Ordinance (TJPV), German text
- Transparency register: questions and answers (in French)
- Commercial register office of Basel-Stadt (in German)
- Commercial register office of Zug, newsletter 3/2026 (in German)
- EasyGov

Information as of 5 October 2026. This article provides general information and is not legal advice.

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