Swiss Transparency Register 2026: Who Must Report, 25% Threshold, Deadlines, Fines and How to File

On 1 October 2026, Switzerland’s new Transparency Register goes live, requiring more than 500,000 legal entities to identify and report their beneficial owners to a central, non-public federal register maintained by the Federal Office of Justice. Enacted through the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners of 26 September 2025, the Swiss transparency register represents the most significant expansion of corporate disclosure obligations in Swiss commercial law in decades. Any natural person who directly or indirectly holds at least 25% of the capital or voting rights, or who otherwise controls an in-scope entity, must be declared, with reports submitted electronically via the EasyGov.swiss platform.

• Start date: 1 October 2026
• Who is affected: Swiss stock corporations (AG/SA), limited liability companies (GmbH/Sàrl), cooperatives, and certain foreign entities with a Swiss nexus
• Beneficial ownership threshold: 25% of capital or voting rights, or control by other means
• Filing platform: EasyGov.swiss
• Initial reporting deadlines: Phased between 1 January 2027 and 1 April 2027 depending on entity type and audit status

What Is the Swiss Transparency Register?

The Swiss transparency register is a central, electronic register of beneficial owners established under the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners. Its primary purpose is to enhance transparency within the Swiss corporate landscape and strengthen the country’s defences against money laundering and terrorist financing. The register is administered by a newly created authority within the Federal Office of Justice, and all submissions are made through the federal government’s EasyGov.swiss online portal.

Unlike some international equivalents, the beneficial owners register in Switzerland is not public. Information held in the register is strictly confidential and cannot be accessed by the general public. This design reflects Switzerland’s longstanding emphasis on privacy while still fulfilling international AML standards.

Who Can Access the Register?

Access to the register is limited to designated authorities and regulated entities with legitimate compliance needs. These include:

• Criminal prosecution authorities conducting investigations
• Tax authorities acting under applicable legal mandates
• MROS (Money Laundering Reporting Office Switzerland) for AML intelligence purposes
• FINMA (Swiss Financial Market Supervisory Authority) in its supervisory capacity
• Financial intermediaries completing their own KYC and AML due diligence checks

No public search facility exists. Companies, journalists and private individuals cannot query the register. This restricted-access model distinguishes the Swiss transparency register from the EU’s Anti-Money Laundering Directive framework, where some member states maintain partially public registers.

Who Must Report, Entity-by-Entity Breakdown

The transparency law in Switzerland casts a wide net. Swiss companies must report beneficial owners if they fall within the categories defined by the Act. The obligation extends to domestic legal entities registered in the Swiss commercial register and to certain foreign entities with a Swiss nexus, such as those operating Swiss branches or owning Swiss real estate.

Exemptions and Special Cases

Listed companies whose equity securities are traded on a recognised stock exchange are exempt because their ownership structures are already subject to disclosure requirements under securities regulation. Associations and foundations are generally exempt as well, reflecting the distinct governance structures of these entities.

However, industry observers expect that certain edge cases will require careful analysis. Nominee shareholders, individuals or entities holding shares on behalf of an undisclosed third party, must disclose the identity of the underlying beneficial owner. Trusts and similar arrangements with a Swiss nexus may also trigger reporting obligations where the trust holds a controlling interest in a Swiss entity. Companies should assess whether any indirect holding structures create a reporting requirement, particularly where multi-layered corporate chains cross the 25% threshold.

Foreign entities with a Swiss branch registered in the commercial register, or foreign entities that own Swiss real estate, also fall within the scope of the Act and must report their beneficial owners to the Swiss transparency register.

Definition of Beneficial Owner and the 25% Threshold

Under the Federal Act, a beneficial owner is any natural person who directly or indirectly holds at least 25% of the capital or voting rights in a legal entity, or who otherwise exercises control over that entity. The 25% threshold for beneficial ownership applies to both capital shares and voting rights, and it encompasses indirect holdings where a natural person’s interest is held through one or more intermediary entities.

Control “by other means” captures situations where a person exercises dominant influence through contractual arrangements, management rights, or comparable mechanisms, even if their formal shareholding is below 25%. This broad definition ensures that the UBO register in Switzerland captures the true controllers of in-scope entities regardless of how their influence is structured.

Worked Examples: Direct, Indirect and Control-Based Ownership

Where no natural person meets the 25% threshold or otherwise controls the entity, the Act requires the entity to report the members of its senior management (typically the board of directors or managing directors) as the persons to be recorded. This fallback ensures that no entity can avoid transparency obligations simply because its ownership is widely dispersed.

Deadlines and Reporting Timeline for the Swiss Transparency Register (2026–2027)

The implementing ordinance, the Transparency Ordinance, published by the Federal Council on 12 June 2026, sets out a phased schedule of initial reporting deadlines. These deadlines depend on the type of legal entity and whether it is subject to a regular (ordinary) audit.

Accelerated One-Month Deadline for New Commercial Register Filings

Any entity that makes a filing with the Swiss commercial register after 1 October 2026, for example, a new incorporation, a change of registered office, or an amendment to the articles of association, triggers a one-month accelerated reporting deadline to the Swiss transparency register. This means that newly incorporated companies cannot wait until the phased deadline applicable to their entity type; they must file UBO information within one month of their commercial register entry.

Industry observers expect this trigger mechanism to have significant practical implications. Companies planning corporate restructurings, mergers, or new subsidiary formations after 1 October 2026 should factor the one-month UBO filing window into their transaction timelines. Failure to submit within this accelerated window carries the same penalty exposure as missing the standard deadline.

Ongoing Reporting Obligations

After the initial filing, entities must keep their transparency register entries up to date. Any change in beneficial ownership must be reported within a defined period. This includes changes resulting from share transfers, capital increases, changes in control arrangements, and corporate reorganisations. Entities should establish internal processes to monitor and flag reportable changes promptly.

What Information Must Be Submitted

The data fields required for each beneficial owner are defined in the Act and the implementing ordinance. For every reportable UBO, the following information must be submitted to the register:

• Full legal name (surname and given names)
• Date of birth
• Nationality (or nationalities)
• Place of residence (city and country)
• Nature and extent of control, specifying whether the person holds capital, voting rights, or exercises control by other means, and the approximate percentage or description of the interest

Supporting documentation must accompany the filing. Depending on the entity and the nature of ownership, this may include copies of identification documents, excerpts from the share register, shareholders’ agreements, or notarial declarations confirming the beneficial ownership chain. Entities should prepare these documents in advance to avoid delays during the filing process.

How to File, Step-by-Step EasyGov Workflow

All reports to the Swiss transparency register must be submitted electronically through the EasyGov.swiss platform, the federal government’s centralised online portal for businesses. There is no paper-based alternative. The following step-by-step guide outlines the filing process for companies preparing to submit their UBO information for the first time.

1. Register on EasyGov.swiss. If the company does not already have an EasyGov account, the authorised representative must create one. Registration requires a valid Swiss corporate identification number (UID) and authentication credentials.
2. Locate the Transparency Register module. Once logged in, navigate to the Transparency Register section within EasyGov. The module is accessible from the main dashboard.
3. Select the reporting entity. Choose the legal entity for which the UBO report is being submitted. The system will pre-populate certain fields from the commercial register, such as the company name, registered office and UID.
4. Enter beneficial owner details. For each UBO, enter the required data fields: full name, date of birth, nationality, residence (city and country), and the nature and extent of the beneficial interest.
5. Attach verification documents. Upload copies of identity documents (passport or national ID card), share register extracts, and any notarial declarations or organisational charts that verify the ownership chain. Accepted formats typically include PDF and common image formats.
6. Review and submit. Review all entered information for accuracy and completeness. Once satisfied, confirm and submit the report. The system will generate a filing confirmation with a reference number.
7. Retain the confirmation. Store the filing confirmation and copies of all submitted documents in the company’s corporate records for future reference and audit purposes.

A company may authorise a third party, such as a lawyer, notary, fiduciary or corporate service provider, to file on its behalf. In such cases, a written power of attorney should be prepared and retained. The EasyGov guidance indicates that companies should register on the platform ahead of their filing deadline to allow adequate preparation time.

Notarisation and Identity Verification

The Act and its implementing ordinance require entities to verify the identity of their beneficial owners using reliable documents and, where appropriate, through notarial declarations. For straightforward ownership structures, a single shareholder holding registered shares, a copy of the share register and a passport copy may suffice. For more complex arrangements involving indirect holdings, nominee structures, or foreign chains of ownership, a notarial declaration confirming the beneficial ownership chain is strongly recommended.

Entities are expected to exercise due diligence in verifying UBO information. The responsibility for accuracy rests with the reporting entity itself, not with the register authority. Submitting incorrect or incomplete information, even inadvertently, can expose the entity and its directors to penalties under the Swiss transparency register framework.

Penalties, Enforcement and Access Rights

The penalties for non-compliance with the Swiss transparency register are significant and include criminal liability. The Federal Act provides for sanctions against both the legal entity and the individuals responsible for meeting the reporting obligations.

• Failure to report. Entities that fail to submit their initial UBO report by the applicable deadline, or that fail to update the register following a change in beneficial ownership, face administrative fines and potential criminal prosecution of responsible individuals.
• Providing false or incomplete information. Intentionally submitting incorrect, misleading, or incomplete UBO information constitutes a criminal offence. Responsible persons, typically directors and officers, may face personal criminal liability.
• Failure by beneficial owners to cooperate. The Act also imposes obligations on the beneficial owners themselves. A natural person who fails to disclose their status as a UBO to the entity, or who provides false information, may be subject to criminal sanctions.

The likely practical effect of these provisions is that companies will need to treat UBO identification and reporting with the same seriousness as their anti-money laundering compliance obligations. Industry observers expect enforcement to follow a risk-based approach in the early phases, with the Federal Office of Justice focusing on systematic non-compliance and wilful concealment rather than minor procedural oversights.

Practical Mitigation Steps

• Maintain internal KYC records. Keep a documented file of UBO identification, verification documents, and the methodology used to determine beneficial ownership.
• Establish change-monitoring procedures. Assign responsibility for monitoring share transfers, capital events, and changes to control arrangements that might trigger an updated filing.
• Retain documents for the statutory period. Ensure that all UBO-related records, including filing confirmations, are retained for at least ten years in line with general Swiss document retention requirements.
• Seek legal advice for complex structures. Where ownership involves multi-layered holding chains, trusts, nominee arrangements or cross-border elements, engage qualified commercial law advisors to assess reporting obligations before the deadline.

Practical Compliance Checklist

Use the following checklist to prepare for your filing to the Swiss transparency register. Companies that complete these steps well ahead of their applicable deadline will minimise the risk of non-compliance.

• Identify all natural persons who directly or indirectly hold 25% or more of the capital or voting rights, or who control the entity by other means
• Collect and verify each UBO’s personal data: full name, date of birth, nationality and residence
• Obtain copies of identity documents (passport or national ID) for each UBO
• Prepare an up-to-date share register extract or equivalent ownership record
• For indirect or complex structures, prepare an organisational chart and, where appropriate, a notarial declaration confirming the beneficial ownership chain
• Draft a board resolution authorising the filing and designating the person or firm responsible for submission
• Register the company on EasyGov.swiss if not already registered
• Complete and submit the UBO report via EasyGov before the applicable deadline
• Retain the filing confirmation and all supporting documents in the company’s compliance records
• Establish an internal process for monitoring and reporting future changes in beneficial ownership

For companies with operations in Switzerland that require tailored guidance, particularly those with cross-border ownership structures or nominee arrangements, engaging a qualified advisor early in the process can prevent costly filing errors and ensure full compliance with the transparency law in Switzerland.

Conclusion

The Swiss transparency register marks a fundamental shift in corporate disclosure requirements for entities operating in Switzerland. With the register going live on 1 October 2026 and initial reporting deadlines beginning in January 2027, companies should be actively preparing their UBO identification, verification and filing processes now. Entities that act early, registering on EasyGov, mapping ownership structures and assembling verification documents, will be best positioned to meet their obligations and avoid the penalties that accompany non-compliance.

Sources

1. Federal Council, Dispatch on Strengthening Anti-Money Laundering Measures (admin.ch)
2. EasyGov, Transparency Register Official Guidance
3. EasyGov.swiss, The Online Desk for Companies
4. FINMA, Swiss Financial Market Supervisory Authority
5. Zefix, Central Business Name Index / Commercial Register