The New Transparency Register in Switzerland: What Companies Need to Know
The TLEA forms part of the revision of Switzerland’s anti-money laundering framework and aims to enhance transparency regarding the ownership and control structures of legal entities. Its objective is to strengthen the fight against money laundering, terrorist financing and the misuse of corporate structures, while ensuring compliance with the international standards of the Financial Action Task Force (FATF).
What is the Transparency Register?
The Transparency Register is a centrally maintained government register in which the beneficial owners of legal entities are recorded. Unlike the Commercial Register, the Transparency Register is not open to the public. Access is limited to the authorities designated by law, financial intermediaries, and advisers subject to the Anti-Money Laundering Act (AMLA), to the extent that they require the information to comply with their statutory obligations.
Who must report what?
Under the Transparency Act, legal entities incorporated in Switzerland are required to report their beneficial owners to the Transparency Register. This includes, in particular, companies limited by shares (Aktiengesellschaften), limited liability companies (Gesellschaften mit beschränkter Haftung), cooperatives (Genossenschaften), and other legal entities designated by the TLEA.
A beneficial owner is the natural person who ultimately owns or exercises control over a legal entity. This is generally the case where a person directly or indirectly holds at least 25% of the share capital or voting rights, or otherwise exercises control over the company. If no such person can be identified, the members of the company’s highest executive or governing body must be reported.
The company is responsible for identifying its beneficial owners and reporting the following information to the Transparency Register: first and last name, date of birth, nationality, municipality and country of residence, as well as information regarding the nature and extent of the control exercised. Responsibility for ensuring compliance with the reporting obligations lies with the head of the company’s highest executive body. In the case of a company limited by shares, this will generally be the chair of the board of directors.
What deadlines apply?
The Transparency Act will enter into force on 1 October 2026. Companies incorporated after the TLEA enters into force must submit the required information to the Transparency Register within one month of their registration in the Commercial Register. Any subsequent changes must likewise be reported within one month of becoming aware of the relevant change.
For legal entities already existing at the time the Transparency Act enters into force, the TLEA provides for transitional periods within which the required reporting must be completed. The applicable transitional deadlines vary depending on the company’s legal form and audit status. Reports to the Transparency Register are generally submitted electronically via the EasyGov platform. Early registration is recommended to ensure that reporting obligations can be fulfilled in a timely manner once the TLEA enters into force.