The Swiss Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, TJPG for short (LTPM in French), entered into force on 1 October 2026. On the same day the Swiss transparency register started operating. Switzerland thereby joins most European countries, which already run central beneficial ownership registers. The revision of the Swiss Anti-Money Laundering Act took effect at the same time.
Who must report
The Act covers legal entities under Swiss law such as companies limited by shares (AG), limited liability companies (GmbH) and cooperatives. It also covers foreign legal entities with a Swiss nexus: those with a branch entered in the Swiss commercial register, those effectively managed from Switzerland and those owning real estate in Switzerland. Listed companies, associations and foundations, among others, are exempt.
Who counts as beneficial owner
Article 4 TJPG is decisive. A beneficial owner is any natural person who ultimately controls a company by holding, directly or indirectly, alone or acting in concert with third parties, at least 25 percent of the capital or votes, or who controls it in another way. If no such person can be identified, the most senior member of the executive body is deemed the beneficial owner. The logic mirrors what Swiss practice has long called the controlling person.
What the company must do
The reporting entity must identify its beneficial owners, verify their identity, document the information and report it to the register via the EasyGov platform. Newly incorporated companies report within one month of their commercial register entry, and changes must also be reported within one month. For existing entities, transitional deadlines started running on 1 October 2026; according to the Federal Office of Justice they range from one month to two years depending on the situation, and foreign legal entities have six months for their first report. Registration and reporting are free of charge.
Who can see the register
The register is not public. Access is limited to certain authorities and to financial intermediaries and advisers acting under their duties under the Anti-Money Laundering Act. It is kept by the Federal Office of Justice, and a control unit within the Federal Department of Finance checks entries for accuracy, completeness and currency. Some functions, such as full register queries and discrepancy reports, will only be enabled later.
What changes compared with the Code of Obligations
The previous internal company disclosure rules under Articles 697j et seq. and 790a of the Swiss Code of Obligations are repealed. Those who complied with them may be able to rely on the transitional rule in Article 49 TJPG, provided the information is still current. The shift is fundamental: the company used to keep an internal list; now it reports to a federal register that is checked.
What it means for trustees and family offices
Family holding and investment companies are typically in scope, foundations are not. Anyone administering structures for families must therefore clarify, company by company, who reports, who supplies the information and which events trigger a change report, such as an estate division or a capital increase. For financial intermediaries the register is an additional source for their own due diligence, not a substitute for it. Our checklist for the transparency register report covers the practical steps.