The essentials at a glance

  • From 1 October 2026, companies limited by shares, GmbHs, cooperatives and further legal forms must report their beneficial owners to the federal transparency register.
  • More than 500,000 legal entities are affected. Associations, foundations, sole proprietorships and partnerships are not subject to the reporting obligation.
  • A beneficial owner is anyone who, alone or in concert, controls at least 25 percent of the capital or votes, or who controls the company by other means.
  • Existing companies have transitional periods of three months to two years, depending on legal form and audit regime. Newly registered companies report within one month.
  • The two-year period shortens to one month as soon as the first change to the commercial register entry occurs after 1 October 2026. A change of registered office or a change on the board of directors is enough.
  • The register is not public. Reports are submitted electronically via EasyGov.
  • Intentional violation of the reporting obligation: fine of up to CHF 500,000.

What that means for practice

  • Clarify the basic question first: is the company, your own or your client's, subject to the reporting obligation, and which deadline applies?
  • Identify the company's beneficial owners: obtain the self-declaration, verify it for plausibility, document it.
  • Assign responsibilities: responsibility lies with the company's supreme governing body, and the company itself submits the report via EasyGov.
  • Plan the report alongside every commercial register change: a change of registered office or a change on the board triggers the one-month deadline.
  • Sensitise your clients: the commercial register office's notice about the shortened deadline is addressed to the company, not to its fiduciary. Ask for such letters to be forwarded without delay.

How Advonis supports you

  • With our deadline check, four questions tell you whether a company is subject to the reporting obligation and which deadline applies.
  • With Advonis' reporting check (coming soon), you enter the ownership structure and receive the beneficial owners with the type and extent of control, as a dated PDF for your own filing.
  • For our customers with many mandates, we are building these clarifications into our platform: from establishing the controlling persons to the ongoing monitoring of reporting deadlines.

In depth

Who has to report, and who does not

Subject to the reporting obligation are the Swiss legal forms whose ownership is not publicly visible: the company limited by shares, the GmbH, the cooperative, the partnership limited by shares, as well as the SICAV, the SICAF and the limited partnership for collective investment. Added to these are legal entities under foreign law if they have a branch entered in the commercial register, if their effective administration is in Switzerland, or if they hold Swiss real estate.

The law exempts three groups: listed companies and their majority-held subsidiaries, pension institutions, and companies held at least 75 percent by public authorities. A tax exemption for charitable purposes is not an exemption.

Not covered are associations, foundations, sole proprietorships and partnerships. Two clarifications: if a foundation or an association controls a company that is subject to the obligation, that company must look through the structure. And trustees domiciled or established in Switzerland have reporting duties of their own, which follow a different regime.

Who is reported

The beneficial owner is the natural person who ultimately controls a company. The law knows two routes. The first is shareholding: at least 25 percent of the capital or votes, alone or in concert with others, held directly or indirectly through intermediate companies. The second is control by other means, for instance the right to appoint or remove the majority of the governing body, veto rights on central matters, or obtaining profit distributions.

If nobody reaches these thresholds, the fallback rule applies: the senior managing official is then deemed the beneficial owner and is reported with their function. That is a regular, correct outcome and not a defect, particularly for companies with widely dispersed shareholders.

What is reported

Per person, the register requires less than many fear: surnames and first names, the date of birth, all nationalities, and the municipality of residence with postal code and country. No street address. The AHV number is not reported; only whether one exists is established, and where it is missing, for instance for persons abroad, a copy of an identity document is attached. Added to this are the type and extent of control: whether the person acts alone or in concert, holds directly or indirectly, and in which band their shareholding lies. For multi-level structures, the chain of control is disclosed as well.

By when

The deadline system has three levels. Companies entered in the commercial register before 1 October 2026 have transitional periods of three to six months, staggered by legal form and audit regime. If all beneficial owners are already visible in the commercial register as members or governing bodies, which in practice mainly concerns the GmbH, the period extends to two years.

That longer period comes with a caveat, however: it shortens to one month as soon as the company makes its first commercial register change after 1 October. So anyone with 2028 in the calendar who changes an address in spring must report four weeks later.

For companies newly registered from 1 October 2026, there is no transitional period, but one month from registration. And after the initial report, changes must be reported within one month of becoming known. In all cases: a month is a month, not 30 days. A period that starts on 15 March ends on 15 April.

How reports are submitted

The report is submitted electronically via EasyGov, the federal online portal, by the company itself. The register is kept by the Federal Office of Justice.

Just as important is what the register is not: public. Access is limited to the control authority and a legally defined catalogue of authorities, plus financial intermediaries and newly subjected advisers, insofar as they need the details for their due diligence duties under the Anti-Money Laundering Act. The general public sees nothing. The company itself can request a confirmation of its entry or an extract at any time, for instance to present to its bank.

What happens in case of violations

Intentional violation of the reporting obligation carries a fine of up to CHF 500,000; mere negligence is not sufficient. Alongside this stands a graduated set of instruments of the control authority: first the demand to remedy, for repeated violations the suspension of the membership and property rights of the defaulting shareholders, and as a last resort the dissolution of the legal entity. The most effective protection is unspectacular: run the clarification properly, document the derivation, know the deadlines.

This article is a guide, not legal advice. Decisive are the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG, SR 955.3) and the associated ordinance (TJPV, SR 955.31), both in force from 1 October 2026.