Switzerland’s new Transparency Register: why businesses should start preparing now

Switzerland is raising the bar on ownership transparency

Corporate transparency remains a key regulatory focus globally, with jurisdictions continuing to strengthen measures designed to combat money laundering, sanctions evasion and financial crime.

Against this backdrop, Switzerland’s new Legal Entities Transparency Act introduces a central Transparency Register for beneficial ownership information from 1 October 2026.

For many organisations, this represents a significant shift. Today, beneficial ownership information is often maintained internally. Under the new framework, in-scope entities will need to report information to a federal register and keep that information up to date throughout the life of the entity.

The register will not be publicly accessible. However, designated Swiss authorities and certain professionals subject to Swiss anti-money laundering (AML) requirements will be able to access the information in prescribed circumstances.

Which organisations could be affected?

The new rules are expected to apply to a broad range of Swiss legal entities, including:

• Companies limited by shares
• Limited liability companies (LLCs)
• Cooperatives
• Société d’Investissement à capital variable (SICAVs)
• Société d’investissement à capital fixe (SICAFs)
• Limited partnerships for collective investments

Certain foreign entities may also be affected where they have a sufficient connection to Switzerland, including through:

• A Swiss branch
• An effective place of management in Switzerland
• Ownership of Swiss real estate

The position is not always straightforward. While listed companies are generally expected to be exempt, and certain subsidiaries may also benefit from exclusions, organisations should avoid assuming they fall outside scope without first reviewing their specific circumstances.

Ultimately, applicability will depend on the legal form of the entity, its ownership structure and the nature of its Swiss nexus.

The real challenge is identifying beneficial ownership

For many businesses, the biggest compliance hurdle will not be the reporting process itself.

The legislation introduces specific criteria for determining beneficial ownership, generally focusing on individuals who directly or indirectly hold at least 25% of capital or voting rights, or who exercise control through other means.

Complex structures can make this analysis challenging.

Where ownership is held through intermediary entities, organisations may need to trace ownership chains through multiple layers before identifying the relevant natural persons. Structures involving trusts, holding companies or cross-border ownership arrangements may require particular attention.

Businesses that rely exclusively on existing internal beneficial ownership registers may discover additional work is needed to align information with the new Swiss requirements.

Key requirements organisations should understand

Some of the headline requirements include:

• Implementation date: 1 October 2026
• Reporting threshold: Generally 25% ownership, voting rights or control by other means. For indirect ownership, control may arise where a person holds more than 50% of one or more intermediary entities that themselves directly or indirectly hold at least 25% of the relevant entity
• Filing channel: Electronic reporting is expected via swiss
• Governance responsibility: Ultimate responsibility remains with the entity’s highest governing body
• Ongoing updates: Changes generally need to be reported within one month
• Register access: Not publicly accessible
• Sanctions: Intentional breaches may result in fines of up to CHF 500,000

Although reporting tasks may be delegated internally or outsourced, accountability for compliance remains with the governing body.

Transparency reforms go beyond ownership reporting

The Transparency Register forms part of a wider package of AML reforms.

From October 2026, certain advisory and structuring activities may become subject to AML obligations, including services connected to:

• The formation and administration of non-operating legal entities
• Certain real estate transactions
• Domicile and registered office services

Financial intermediaries should also anticipate increased scrutiny around sanctions controls, ownership documentation and AML risk assessment processes.

Organisations affected by both the Transparency Register requirements and the wider AML reforms may wish to consider these changes together when assessing future compliance obligations and operational processes.

Why acting early matters

Although the new regime does not take effect until October 2026, preparation should start well before then.

Transitional arrangements will apply to existing entities, but deadlines vary depending on factors such as legal form, audit status and existing commercial register records.

For some organisations, the first compliance deadlines could fall as early as 31 December 2026. Other entities may have until early 2027, while entities whose beneficial owners are already registered as partners or corporate bodies may benefit from a longer transitional period. Changes to commercial register entries after 1 October 2026 can, however, accelerate reporting timelines.

Experience from similar transparency regimes in other jurisdictions suggests that identifying beneficial owners, collecting supporting information and validating ownership structures often takes significantly longer than expected, particularly for large or international groups.

Early preparation can help avoid last-minute remediation exercises and reduce the risk of compliance failures once reporting obligations begin.

Practical steps to take now

Organisations should consider taking the following actions:

• Confirm which Swiss or Swiss-connected entities could fall within scope
• Map ownership and control structures across the organisation
• Identify beneficial owners under the new rules rather than relying solely on existing records
• Collect and validate required ownership and identification information
• Review governance processes for monitoring and reporting ownership changes
• Assess whether related AML reforms could affect existing service offerings or operating models
• Assign responsibility for future reporting and compliance oversight
• Prepare early for EasyGov.swiss registration and allocation of internal filing responsibilities

How IQ-EQ can help

Preparing for the new Transparency Register involves more than completing a filing. Organisations need confidence that they have correctly identified beneficial owners, documented ownership chains and established governance processes capable of supporting ongoing compliance.

IQ-EQ’s Swiss corporate services team supports clients with entity scoping, ownership and control mapping, governance reviews, ongoing corporate administration and readiness assessments linked to the wider AML reforms.

Get in touch today to discuss how Switzerland’s new Transparency Register could affect your organisation.

Frequently asked questions