AGN EMEA Tax Committee News
Is your business ready for Switzerland’s new Transparency Register? This article explains what you need to know before it comes into effect in October 2026.
Following recommendations from the Financial Action Task Force (FATF), the Swiss Parliament adopted the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners in September 2025. The Federal Council has confirmed that the new legislation, together with related anti-money laundering amendments, will enter into force on 1 October 2026.
For the first time, Switzerland will introduce a centralised federal register of beneficial owners. Swiss companies, family holdings, fiduciary structures and certain foreign entities with a Swiss nexus will face new compliance obligations and may need to review their ownership and control structures.
Why Is Switzerland Introducing a Transparency Register?
The reform is part of a broader effort to strengthen Switzerland’s anti-money laundering framework and align it with international standards.
Although transparency requirements were enhanced in 2014, international bodies continued to criticise the Swiss system for not providing authorities with sufficiently rapid and reliable access to beneficial ownership information.
The new legislation aims to:
- Improve the identification of individuals who ultimately control legal entities;
- Strengthen the fight against money laundering, terrorist financing and corruption;
- Align Switzerland with FATF Recommendation 24 and other international transparency standards;
- Enhance the integrity and reputation of the Swiss financial centre.
Which Entities Are Affected?
The scope of the new legislation is broad.
In principle, the reporting obligation applies to:
- Swiss corporations (AG/SA);
- Limited liability companies (GmbH/Sàrl);
- Cooperatives and certain investment vehicles;
- Foreign entities with a sufficient Swiss connection, such as a Swiss branch, an effective place of management in Switzerland, or Swiss real estate holdings.
The following entities are generally exempt:
- Listed companies;
- Subsidiaries largely owned by listed companies;
- Foundations;
- Associations;
- Certain public bodies and pension institutions.
For most privately held Swiss SMEs, however, the new rules will be directly relevant.
Who Is a Beneficial Owner?
Entities must identify the natural persons who ultimately control the company.
Generally, a beneficial owner is an individual who directly or indirectly holds at least 25% of the capital or voting rights, whether alone or together with others. Control may also arise through other arrangements, even if this ownership threshold is not met.
If no beneficial owner can be identified under the statutory criteria, a senior managing individual may need to be reported.
Affected entities will be required to:
- Identify their beneficial owners;
- Verify the accuracy of the information collected;
- Maintain up-to-date records;
- Submit the information to the federal transparency register;
- Update the register whenever relevant changes occur.
The register will not be publicly accessible. Access will be limited to designated authorities and certain professionals subject to Swiss anti-money laundering legislation.
This approach seeks to balance greater transparency with Switzerland’s longstanding commitment to privacy and data protection.
Key Implementation Dates
The legislation will enter into force on 1 October 2026, and the new register is expected to become operational through the federal EasyGov platform.
Transitional periods will apply to existing entities. According to current guidance, many companies will need to complete their first filings between January and April 2027. A simplified procedure may remain available until October 2028 where beneficial ownership information is already reflected in the commercial register.
Although these deadlines may seem distant, reviewing ownership structures—particularly within family groups, holding structures and cross-border arrangements—can be a complex and time-consuming exercise.
What Happens in Case of Non-Compliance?
The new regime will be supported by enhanced enforcement powers and meaningful sanctions.
Entities that fail to identify beneficial owners, submit inaccurate information or update the register when required may face:
- Administrative measures;
- Financial penalties;
- Criminal liability in certain cases.
Authorities will also have the power to verify compliance and require corrective action.
The reform should therefore be viewed not merely as a filing requirement, but as a broader governance and compliance obligation.
Practical Implications for Businesses
The new law goes well beyond a simple reporting exercise.
Many businesses will need to:
- Review shareholder and governance structures;
- Document indirect ownership chains;
- Verify control arrangements;
- Implement internal monitoring procedures;
- Coordinate information among shareholders, directors, fiduciaries and advisers.
Groups with international ownership structures may face particular challenges when tracing beneficial ownership across multiple jurisdictions. Family offices and privately held groups should ensure that supporting documentation is sufficiently robust to withstand future regulatory scrutiny.
From both a governance and compliance perspective, the reform reflects the continuing global trend towards greater corporate transparency.
Final Remarks
The introduction of Switzerland’s transparency register represents one of the most significant corporate governance reforms in recent years.
For many businesses, particularly privately held Swiss companies, compliance will require more than a simple administrative filing. The new framework demands a clear understanding of who ultimately controls a legal entity and how that control is exercised.
Organisations that begin preparing now will be best positioned to comply efficiently with the new requirements and navigate the evolving international transparency landscape.
Brought to you by the AGN EMEA Tax Committee
If you have any questions in relation to this article, please get in touch with Rocco.
Rocco Arcidiacono
Partner & Swiss certified tax expert, TEP
Fiduciaria Mega SA
Email: [email protected]
