On 1 October 2026 the Swiss Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners entered into force, TJPG for short (glossary). On the same day the Swiss transparency register started operating, after a pilot phase in which, according to the Federal Office of Justice, around 2,500 companies reported voluntarily. At the same time the revision of the Swiss Anti-Money Laundering Act took effect, extending the circle of obliged persons to certain advisory activities.
For most Swiss companies the TJPG means a one-off report with occasional changes. For families with several companies, for trustees administering such structures and for family offices it is an ongoing task. This article sets out the obligations and describes what needs to be organised now. It does not replace legal advice in an individual case.
Who is covered
Legal entities under Swiss law must report, in particular companies limited by shares (AG), limited liability companies (GmbH) and cooperatives. Foreign legal entities with a Swiss nexus are covered too: those with a branch entered in the commercial register, those effectively managed from Switzerland and those owning real estate in Switzerland. Listed companies, associations and foundations, among others, are exempt.
For family structures this means: the family holding, the property company and the investment company are typically in scope. The family foundation is not. A foreign company holding a property in Switzerland is, even without any other Swiss link. That last point is easily overlooked.
Who counts as beneficial owner
Article 4 TJPG defines the beneficial owner as a 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 by controlling it in another way. If no one can be identified, the most senior member of the executive body is deemed the beneficial owner.
Anyone working with Swiss banks knows this logic as establishing the controlling person. It was kept deliberately similar. Three points still deserve attention. First, indirect control through chains: holding 60 percent of a holding company that holds a majority in a subsidiary means controlling the subsidiary too. Second, acting in concert: family members each holding 15 percent who vote jointly under a shareholders’ agreement can control together. Third, control in another way, through veto rights or financing, which appears in no share register.
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. Reports are filed via EasyGov, and registration is free. Newly incorporated companies report within one month of their commercial register entry; changes to beneficial owners must also be reported within one month.
For existing entities, transitional deadlines have been running since 1 October 2026. The Federal Office of Justice puts them at between one month and two years depending on the situation. Foreign legal entities have six months for their first report (Art. 53 TJPG). The deadline for a specific company should not be guessed but established from the transitional provisions and the Federal Office of Justice FAQ, and recorded.
The previous internal disclosure rules under Articles 697j et seq. and 790a of the Code of Obligations are repealed. Those who complied correctly may be able to rely on the transitional rule (Art. 49 TJPG), provided the information is still current. The old share register is therefore a good starting point, but not a substitute for review.
Who can see the register
The register is not public. Certain authorities and financial intermediaries and advisers acting under their anti-money laundering duties have access. It is kept by the Federal Office of Justice, and according to the Office the data is stored exclusively on a server in Switzerland. A control unit within the Federal Department of Finance checks accuracy, completeness and currency. Some functions, including full register queries and discrepancy reports, will only be enabled later, to protect capacity in the initial phase.
Discrepancy reporting deserves a second look. Once available, financial intermediaries can report when their own finding differs from a register entry. In practice that means: what a company reports to the register and what its bank recorded on Form K or Form A become comparable. Inconsistencies nobody noticed so far will surface.
What trustees and family offices should organise now
The duty lies with the company. But whoever administers structures for families will in practice do or coordinate the work. Five questions should be answered per mandate:
- Which entities in the structure must report, which are exempt, and on what grounds?
- Who is the beneficial owner of each company, and how is that derived, including chains and agreements?
- Who reports, who supplies the information, and who checks the result?
- Which events trigger a change report, and who notices them in time?
- Do the register report, bank documents and internal records match?
The fourth question is the hardest. Changes in control often happen incidentally in families: an estate division, a gift of shares to the next generation, a capital increase, a new shareholders’ agreement, a new intermediate holding. Without systematically linking those events to the reporting duty, the one-month deadline will be missed. A practical sequence with verifiable criteria is in our checklist for the transparency register report.
The register does not replace your own due diligence
For financial intermediaries, and now also for advisers, the register is an additional source, not a substitute for their own determination under anti-money laundering law. Whoever runs a business relationship must establish and verify the beneficial owner themselves, as part of KYB for companies and with the appropriate forms. The register helps with cross-checking; discrepancies are a reason to ask questions. For domiciliary companies there is the added point that the register asks about control, while the bank asks about entitlement to the assets. Both answers can legitimately differ, but must be explainable.
Where software helps and where it does not
The report itself runs through EasyGov; nobody needs additional software for that. The groundwork is the problem: a current, traceable picture of the structure, the people and their roles, with documents and history. Those keeping it in spreadsheets and email folders reconstruct it from scratch at every report. In FLIORE, our family office operating system, each person is recorded once, with their roles in companies, trusts and foundations and the history of those roles; beneficial owners are assessed against the rules of their jurisdiction. That replaces neither the report nor legal assessment in doubtful cases, but it makes both faster and more consistent.
Perspective
The TJPG is not a special regime for the wealthy but part of the international standards against which Switzerland will be measured in its next FATF mutual evaluation. For well-run structures it is a formality with upkeep. For structures whose control relationships exist only in individual people’s heads, it is the occasion to finally record them. Our glossary explains the related terms, from controlling person to the EU AMLR, the European counterpart from 2027.