Checklist: reporting to the Swiss transparency register (TJPG)
For: Swiss companies, trustees and family offices
Updated: 2026-10
A TJPG report works in eight steps: confirm the reporting duty per entity, establish the applicable deadline, derive beneficial owners under Article 4 TJPG, verify their identity, document the derivation, file via EasyGov, define triggers for change reports and reconcile the register report with bank and company records.
Since 1 October 2026 the Swiss Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) has been in force, and the Federal Office of Justice’s transparency register is operating. The report itself is free and digital; the effort lies in the derivation and in ongoing upkeep.
This checklist is written for companies reporting themselves and for trustees and family offices coordinating reports for several companies of one family. Each step states how you know it is done.
The checklist
- 01
Confirm the reporting duty per entity
For each company in the structure, record whether it is covered: Swiss legal entities such as AG, GmbH and cooperatives; foreign legal entities with a branch in the commercial register, effective management in Switzerland or real estate in Switzerland. Record exemptions such as listing, association or foundation with reasons.
Done when: A list of all entities exists, each marked as reporting or exempt with a one-sentence reason.
- 02
Establish the applicable deadline
Newly incorporated companies have one month from their commercial register entry, changes one month from the change. For existing entities, determine the transitional deadline from the transitional provisions and the Federal Office of Justice FAQ; foreign legal entities have six months from entry into force for their first report.
Done when: Each reporting company has a concrete date by which the report must be filed, with the source of the calculation.
- 03
Derive the beneficial owners
Under Article 4 TJPG, check which natural persons hold, directly or indirectly, alone or in concert, at least 25 percent of capital or votes, and who controls the company in another way. Work through ownership chains and take shareholders’ agreements and veto rights into account. If no one can be identified, determine the most senior member of the executive body.
Done when: For each company every beneficial owner is named, with the chain or means of control that produces the result.
- 04
Verify identity and obtain information
Obtain the required personal details from those involved and verify identity with suitable documents. The company depends on their cooperation; make requests in writing with a deadline.
Done when: For each beneficial owner the details and proof of identity are on file, with the date of verification.
- 05
Document the derivation
Record the reasoning, the documents used such as share register, agreements and organisation chart, and open points in one file per company, so that a check by the Federal Department of Finance’s control unit is traceable.
Done when: A third party can follow from the file, without asking, why exactly these persons are reported.
- 06
File via EasyGov
Register the entity once on EasyGov in the transparency register and report the beneficial owners. Set up access so that more than one person can file.
Done when: The filing confirmation is in the file, and at least two authorised persons have access.
- 07
Define triggers for change reports
Name the events that can trigger a change report: share transfer, estate division, gift, capital increase, new shareholders’ agreement, new intermediate company, change in the executive body where the fallback rule applied. For each event, decide who notices it and who files within one month.
Done when: A list of triggers with a responsible person exists and is known to those involved.
- 08
Reconcile with bank and company records
Compare the reported persons with the information given to banks, for example on Form K or Form A, and with the internal share register. Resolve discrepancies before financial intermediaries detect them via the register or later discrepancy reporting.
Done when: Register report, bank documents and internal records match, or every discrepancy is documented with reasons.
Common mistakes
- —Foreign companies holding Swiss real estate are overlooked because they have no other Swiss link.
- —Joint control through a shareholders’ agreement is ignored because no single person holds 25 percent.
- —The report is filed but nobody is responsible for changes; the one-month deadline passes at the next estate division.
- —The register report and the information given to the bank contradict each other because different people prepared them without reconciling.
- —The fallback report of the most senior board member is chosen because the actual derivation is laborious.
What this checklist does not cover
- —This checklist is not legal advice. For complex structures, trusts, joint control or doubts about the reporting duty, consult a specialised law firm.
- —It reflects the legal position as of October 2026. Implementing provisions, the practice of the Federal Office of Justice and the control unit, and register functions continue to evolve; the Act, the ordinance and transpareg.admin.ch are authoritative.
- —It covers the company’s reporting duty. It does not fulfil the own due diligence duties of financial intermediaries and advisers under the Anti-Money Laundering Act.
- —Criminal or administrative consequences of breaches are not assessed here.
Parent service: Digital Transformation
FAQ
Do foundations have to register?
No, foundations are exempt from the transparency register, as are associations and listed companies. Companies held by a foundation may, however, be subject to reporting themselves.
Is the Swiss transparency register public?
No. Certain authorities and financial intermediaries and advisers acting under their anti-money laundering duties have access.
What does the report cost?
According to the Federal Office of Justice, registering on EasyGov and entry in the transparency register are free of charge. Effort arises in derivation and documentation.
Does an earlier disclosure under the Code of Obligations still count?
The 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 if the information is current. That does not automatically replace the register report.
Who checks the entries?
A control unit within the Federal Department of Finance checks entries for accuracy, completeness and currency. The register is kept by the Federal Office of Justice.
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