From 1 October 2026, many Swiss companies will have to report their beneficial owners to a new federal register. Swiss limited companies (SA/AG) and limited liability companies (Sàrl/GmbH) are directly affected, including businesses with straightforward ownership structures.
The aim is to identify the natural persons who ultimately control each company. For an SME owned directly by its founders, the process should usually be manageable. It still requires verified information, supporting records and attention to the applicable deadline.
What your company needs to do
If you run a Swiss limited company or LLC, start with these points:
Establish who ultimately owns or controls the company. A natural person generally qualifies as a beneficial owner when they control at least 25% of the capital or voting rights, directly or indirectly. Control exercised by other means must also be considered.
Collect and verify the required information. This includes identity, date of birth, nationality or nationalities, residence information and the nature and extent of each beneficial owner’s control.
Document the assessment. Copying the shareholder list is not always enough. The company must be able to explain why the people reported qualify as its beneficial owners.
Prepare access to EasyGov. You can create a personal AGOV account, link your company to EasyGov and start the authorisation process in advance. Validation may take several days.
File within the deadline that applies to your company. Existing companies have transitional periods ranging from three months to two years, depending on their circumstances. A first commercial register amendment after 1 October 2026 can trigger a one-month filing deadline earlier than that maximum period.
Keep the information current. Changes to registered information generally have to be reported within one month after the company becomes aware of them.
Initial registration, updates and deletion are free. Certain LLCs and single-shareholder limited companies can use a simplified procedure if all the official conditions are met.
What is the Swiss transparency register?
The Swiss transparency register is a central federal register containing information about the beneficial owners of entities within its scope. You may also see it described in English as a beneficial ownership register.
Its legal basis is the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, referred to here by its French abbreviation LTPM. The Act and its implementing ordinance, referred to here as OTPM (in French), enter into force on 1 October 2026.
The Federal Office of Justice maintains the register. A supervisory authority within the Federal Department of Finance checks that the information is accurate, complete and current.
The transparency register is not public
The word “transparency” does not mean open public access. Unlike the Swiss commercial register, the new register cannot be searched freely by anyone.
Access is limited to the authorities specified by law and certain financial intermediaries and advisers performing their statutory duties. Customers, competitors and members of the public cannot freely search for your company’s beneficial owners.
The company can receive confirmation of its registration and request an extract concerning its own entry. The official TranspaReg questions and answers (in French) explain who may access the register and what information must be reported.
Why is Switzerland introducing this register?
The register is intended to help authorities identify the people who ultimately control legal entities and support efforts against money laundering, terrorist financing, corruption and sanctions evasion.
For entrepreneurs, the practical obligation is to identify, verify, document and report the natural persons who control their company.
Which entities are covered?
The LTPM covers, among others:
Swiss limited companies (SA/AG) ;
partnerships limited by shares;
cooperatives;
certain collective investment entities;
certain foreign legal entities with a qualifying connection to Switzerland.
A foreign legal entity may be covered if it has a branch entered in the Swiss commercial register, has its effective administration in Switzerland, or owns or acquires Swiss real estate within the statutory scope. A foreign parent company should therefore review its own obligations separately from those of a Swiss subsidiary.
Are sole proprietorships covered?
A sole proprietorship is not a legal person separate from its owner. It is therefore not itself one of the entities required to report to the transparency register.
This is one of the differences to consider when deciding between a sole proprietorship and a Swiss LLC.
Which entities are exempt?
The Act exempts certain entities, including:
entities whose participation rights are listed on a stock exchange;
subsidiaries held directly or indirectly more than 75% by one or more qualifying listed entities;
certain supervised occupational pension institutions;
legal entities whose participation rights are held directly or indirectly at least 75% by public bodies.
Check the precise conditions before relying on an exemption. Membership of a corporate group, or having a public body among the shareholders, does not by itself establish that the company is exempt.
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Who is a beneficial owner in Switzerland?
A beneficial owner is always a natural person: an individual who ultimately controls the entity.
In a straightforward business, this will usually be an LLC member or a shareholder of a limited company. Where ownership involves a holding company, several entities or a nominee arrangement, the assessment must trace the chain to the individuals exercising ultimate control.
The 25% capital or voting-rights threshold
A person generally qualifies where, alone or acting together with others, they control: at least 25% :
of the company’s capital ; or
its voting rights.
Exactly 25% meets the threshold. Do not exclude a person merely because they own no more than one quarter.
Here are some straightforward examples:
These examples assume that voting rights match capital ownership, ownership is direct and no agreement gives anyone additional control.
Capital ownership is not the only test
Someone may control a company without owning 25% of its capital. Voting rights and control through other arrangements must also be examined.
Relevant arrangements may include:
a veto over important decisions;
the ability to appoint a majority of the governing body;
decisive influence under a shareholders’ agreement;
an agreement to exercise votes together;
options or other instruments conferring particular control rights;
control arising through a nominee or fiduciary arrangement.
If your company has a shareholders’ or members’ agreement , assess how it affects actual control instead of relying only on the share percentages.
What if nobody reaches 25%?
Consider a limited company owned by five shareholders with 20% each. If none has special rights and there is no joint or indirect control, no individual satisfies the primary test.
In that situation, the most senior member of the managing body is treated as the beneficial owner under the statutory fallback rule. It does not mean that nobody needs to be reported.
This differs from a company that cannot identify or verify its beneficial owners despite making enquiries. In that case, it must report the identification or verification difficulty and provide the relevant information it has. The fallback rule is not a substitute for investigating an unclear ownership structure.
What must a Swiss SA or LLC do in practice?
The process can be organised into five steps.
1. Identify the owners and the people exercising control
Start with an accurate picture of ownership and voting rights:
who holds the shares or membership interests;
the percentage of capital held by each person;
the percentage of voting rights held;
whether ownership is direct or indirect;
whether a person acts for themselves or on behalf of someone else;
whether a contract or special right changes who controls the company.
For an LLC owned directly 60/40 by two individuals, the analysis is relatively straightforward. For a limited company owned through a holding company, you need to trace the ownership and control chain.
For the distinction between owners and directors, our article on Swiss company managers, shareholders and signing authority explains the different roles.
2. Verify the beneficial owners’ identities
The company must apply diligence appropriate to the circumstances. It may request information and supporting documents from shareholders, LLC members, beneficial owners and others involved in the control chain.
For each beneficial owner, prepare the relevant identifying and control information:
surname and given names;
date of birth;
nationality or nationalities;
current residence information and supporting identity documents where required;
country of residence;
municipality and postal code of residence;
the nature of the control exercised;
the extent of control, including the relevant participation band or other control arrangement.
The person submitting the filing must also provide their name, role within or relationship to the company, and email address. Follow the current official form for the precise fields and any additional identity verification requirements.
3. Document and retain the assessment
Keep records showing how the beneficial owners were identified and verified. Depending on the structure, these may include the share or members’ register, an ownership table, a group chart, relevant agreements and the documents used to verify the information.
The information must remain accessible in Switzerland. Records relating to a person must generally be retained for ten years after they cease to be a beneficial owner.
4. Submit the information to the transparency register
Reporting is generally electronic. The federal EasyGov platform lets companies prepare access to the Swiss transparency register (in French).
. The process includes:
creating a personal AGOV account;
linking the EasyGov user account to the company’s Swiss UID;
obtaining the company’s authorisation for that access;
submitting the filing on the company’s behalf.
Access validation can take several days. Prepare the account and company authorisation before the filing deadline.
The most senior member of the managing body is responsible for the reporting process. They may delegate it internally or to an external professional, such as a fiduciary. The company must still ensure that the filing is complete and correct.
5. Keep the registered information up to date
The obligation continues after initial registration. Changes to registered facts generally must be reported within one month after the company becomes aware of them, subject to the statutory arrangements for information updated automatically.
A review may be needed after:
a sale or transfer of shares or membership interests;
a holding moves above or below the 25% threshold;
voting rights change;
an agreement affecting control is signed or amended;
a beneficial owner changes;
a reported person’s name, nationality or place of residence changes.
Include this check in your processes for ownership changes and commercial register amendments.
Need to update your company’s commercial register entry?
Whether you are changing the registered office, company name, manager or director, Entreprendre.ch prepares and submits the amendment documents.
How does simplified reporting work?
Certain companies whose relevant ownership information is already available in the commercial register may use a simplified procedure. The relevant information is then taken through the commercial register process, subject to the official conditions.
Simplified reporting for an LLC
A Swiss LLC may use the simplified procedure when all the official conditions are met, including:
all members are natural persons;
the people to be reported are those same members;
each person to be reported holds at least 25% of the capital;
the company is not in liquidation, bankruptcy or a composition moratorium.
For example, an active LLC owned directly 60% by Pierre and 40% by Julie should generally fit this simple case, provided no other arrangements change who must be reported.
Simplified reporting for a single-shareholder limited company
A single-shareholder SA/AG may also qualify where:
it has only one shareholder;
that shareholder is a natural person;
the same individual is entered in the commercial register as its sole board member;
that individual is its only beneficial owner;
the company is not in liquidation, bankruptcy or a composition moratorium.
A company with one shareholder but several board members does not meet those conditions. Our article on Swiss limited companies.
When is an individual assessment needed?
Take particular care where the structure includes:
a holding company or another corporate shareholder;
indirect ownership;
a foreign company;
a trust, foundation or fiduciary arrangement;
a nominee shareholder;
voting rights that differ from capital ownership;
an agreement giving someone special powers;
veto or appointment rights;
control exercised jointly;
a dispute about ownership or control;
liquidation, bankruptcy or a composition moratorium.
In these situations, clarify the legal structure before deciding which individuals to report. A percentage-only calculation may miss the person exercising ultimate control.
What are the Swiss transparency register deadlines?
The LTPM takes effect on 1 October 2026. The filing deadline then depends on when the company was incorporated, its legal form and audit status, and the information already entered in the commercial register.
Companies incorporated from 1 October 2026
A newly registered Swiss company generally has one month to file, calculated from publication of its commercial register entry in the Swiss Official Gazette of Commerce (SOGC).
Transitional periods for existing companies
For companies registered before the Act takes effect, Article 51 LTPM provides the following maximum transitional periods:
Apply the statutory categories carefully. In particular, check that every actual beneficial owner is already entered in the commercial register in the capacity required for the two-year period. Have an uncertain audit classification checked before choosing a deadline.
A commercial register amendment can bring the deadline forward
An existing company that makes its first amendment to its commercial register entry after 1 October 2026 generally has to report to the transparency register within one month of that amendment, even if its maximum transitional period would otherwise run longer.
Changing the registered office, name, purpose, manager or director may therefore accelerate the deadline. If you plan a company amendment in late 2026 or 2027, prepare the beneficial ownership information at the same time.
How much does transparency register filing cost?
Initial registration is free. Updating an entry and deleting an entry are also free.
Fees can apply to reminders, formal notices, authority decisions and register extracts. A registration confirmation remains free.
For a small business, the main cost is therefore usually the time needed to identify, verify and document the right people, plus any professional assistance. A directly owned 60/40 LLC is likely to require less work than a group with several ownership layers.
What are the consequences of non-compliance?
Reporting is a legal obligation. An honest mistake is different from an intentional violation, but companies should document their enquiries and correct inaccurate information promptly.
The LTPM provides for fines of up to CHF 500,000 for certain intentional breaches of reporting or cooperation duties and certain false statements. Failure to comply with a final authority decision can also be sanctioned.
Start early, retain evidence, disclose unresolved identification issues and update the register when required. These practical steps help reduce avoidable errors.
Checklist: prepare your Swiss company now
You can prepare before 1 October 2026. Work through the following steps:
Common mistakes to avoid
✕ Treating the threshold as more than 25%
Exactly 25% meets the test. Four people who each own one quarter may therefore all qualify as beneficial owners.
✕ Reporting a holding company as the ultimate beneficial owner
A company cannot be the ultimate natural-person beneficial owner. Where a holding company is involved, trace the chain to the individuals exercising ultimate control, applying the relevant statutory rules and exemptions.
✕ Looking only at share capital
Voting rights and other means of control also count. A shareholders’ agreement or veto right may change the analysis.
✕ Assuming a commercial register entry always fulfils the obligation
The commercial register and transparency register are separate. Simplified reporting is available in specified cases, but the company must verify that it meets all the conditions.
✕ Leaving EasyGov access until the filing deadline
Company authorisation must be validated. This can take several days, so prepare it in advance to avoid an administrative delay.
Prepare the ownership records and establish your deadline
The Swiss transparency register adds a reporting obligation for SA/AG companies and LLCs. For many directly owned SMEs, the process is straightforward: identify the individuals who control at least 25% of capital or votes, check other forms of control, verify their information and document the filing.
Greater care is needed where ownership is indirect or control differs from share percentages. Holding companies, special shareholder rights, nominee arrangements and foreign entities need an assessment of the full control chain.
Preparing before 1 October 2026 helps avoid reconstructing the records under time pressure, particularly if a commercial register amendment triggers a one-month deadline.
Use the checklist as a starting point, then confirm whether your company qualifies for simplified reporting. Where the structure is complex or a beneficial owner cannot be verified, obtain an individual assessment and follow the official reporting procedure for that situation.
Reviewed against official information available on 22 September 2026. This article provides general information and does not replace legal advice on a particular ownership structure or filing deadline.
FAQ: the Swiss transparency register
Is the Swiss transparency register public?
No. Access is restricted to the authorities and professional categories specified by law for the performance of their statutory duties. It is not a public company-owner search service.
Must a Swiss LLC report its beneficial owners?
Generally, yes. A Sàrl/GmbH falls within the LTPM. Simplified reporting may be available where all members are individuals, the people to be reported are those members holding at least 25% of the capital, and the other official conditions are met.
Must a Swiss limited company register?
Yes, unless a specific exemption applies. Certain single-shareholder SA/AG companies may qualify for simplified reporting where the sole individual shareholder is also the sole registered board member and only beneficial owner.
Does a sole proprietor have to register?
Generally, no. A sole proprietorship is not a separate legal person and is not itself subject to this reporting obligation.
Does exactly 25% make someone a beneficial owner?
A person who controls exactly 25% of the capital or voting rights reaches the statutory threshold. The test also covers indirect control and control by other means.
What should the company report if nobody owns 25%?
First check voting rights, joint arrangements and other means of control. If no individual meets the primary criteria, the most senior member of the managing body is reported under the fallback rule. Inability to identify a real beneficial owner is a different situation and must be reported accordingly.
Is an EasyGov transparency register filing free?
Initial registration, changes and deletion are free. Certain reminders, decisions and extracts may be subject to fees.
Can an accounting firm submit the filing?
Yes. The responsible senior manager may delegate the process internally or to a third party. The authorised person needs appropriate access, and the company remains responsible for the quality and completeness of its information.
How quickly must a change be reported?
Relevant changes generally must be reported within one month after the company becomes aware of them, subject to statutory automatic-update arrangements. Changes may concern identity, residence or the nature and extent of control.
What if a holding company owns the business?
Trace the ownership and control chain to the individuals exercising ultimate control. Apply any relevant statutory exemptions or special rules, and obtain an individual assessment where the structure is unclear.
Founder of Entreprendre.ch, Romain helps Swiss entrepreneurs establish and manage their companies, from LLCs to limited companies. He makes administrative and legal procedures easier to understand.
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