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Alexander Vogel
Camillo Devecchi
On 1 October 2026, the new Federal Act on the Transparency of Legal Entities will enter into force. Companies will have to report their beneficial owners (BO) to a central transparency register. This factsheet provides a concise overview of the key requirements, deadlines and practical steps.
What is it about?
- New central, non-public register at Federal Office of Justice concerning BO of companies.
- Objectives: prevention of money laundering, organised crime and terrorism financing.
- Comparable registers already exist in other coun-tries (including EU/EEA states).
When will the new rules apply?
- Entry into force: 1 October 2026.
- Staggered transitional periods for initial reporting (see section Transitional periods).
Who is affected?
- Swiss companies: AG, GmbH, KmAG, cooperatives, SICAV, SICAF and KmGK.
- Foreign legal entities with a Swiss connection.
- Exemptions (among others): listed companies (and >75%-owned subsidiaries); pension schemes.
Who is a beneficial owner?
- Natural person holding ≥ 25% of capital or voting rights, or exercising control in another way.
- Indirect control: 25% at 1st level, and > 50% for each intermediate entity from 2nd level onwards.
- As fallback: highest-ranking member of governing body.
Companies’ obligations
- Identify, verify and document BO.
- Reporting to the register; subsequent reporting of changes within 1 month.
What data must be reported?
- Name, date of birth, nationality, address, type/scope of control.
- AHV no. or copy of passport/ID/foreign national’s identity document.
- If no identification: available information + contact person.
Shareholders’/members’ obligations
- Report BO to company within 1 month of control arising.
- Subsequent reporting of changes within 1 month.
Responsibility and delegation
- Responsible: highest-ranking member of governing body (in particular, chair of board of directors).
- Delegation to third parties (e.g. lawyers) possible; ultimate responsibility remains.
- Group: each entity separately.
How is reporting carried out?
- Electronically via «EasyGov – Swiss Transparency Register».
- Authorisation of at least one person required.
- Simplified procedure for simple structures (e.g. one-person AG).
Transitional periods for initial reporting
| AG with ordinary audit | 3 months |
| AG without ordinary audit | 5 months |
| Other companies with ordinary audit | 4 months |
| Other companies without ordinary audit | 6 months |
| Foreign legal entities | 6 months |
| All BO already registered in CR | 2 years |
- Any commercial register change after 1 October 2026 shortens period to 1 month.
- Newly formed entities: 1 month after registration in commercial register.
Access
- Not public. Access only for Control Office, certain authorities and financial intermediaries.
Penalties - Fine of up to CHF 500,000 for intentional breach of reporting/information obligations.
- Fine of up to CHF 100,000 for failure to comply with an order of Control Office.
- Last resort: suspension of rights, dissolution of company.
What needs to be done now?
- Contact shareholders/members to clarify control relationships.
- Identify BO and document chains of control.
- Appoint and register authorised persons.
- Report BO to Transparency Register.
- Establish internal processes/responsibilities for on-going updates.
- Carefully plan forthcoming commercial-register changes in light of shortened reporting period.
| MLL Legal supports you in analysing ownership structures, identifying BO, and preparing and submitting reports. You may authorise us to submit reports and monitor changes. We would be pleased to discuss specific steps required in your case.
This factsheet provides a general and partially simplified overview (as at August 2026) and does not replace legal advice in individual cases. |
