Switzerland's transparency register: which deadlines run and what your bank may check against it

Since 1 October 2026 Switzerland has kept a central register showing who stands behind a company. On that day the Federal Act on the Transparency of Legal Entities (TJPG, in its German abbreviation) and the revised Anti-Money Laundering Act entered into force, and the Swiss transparency register began operating. Deadlines have been running ever since. For some companies they are a few months; for foreign companies with a Swiss connection the deadline ends on 1 April 2027.

Two weeks after the launch, the Federal Council also took note of the third national report on the risks of money laundering and terrorist financing. Among other things it recommends assessing how effective the new register is and adjusting it where necessary. Anyone who holds a Swiss company, runs a business account in Switzerland or owns Swiss property through a company should know the new rules. They cover not only the filing itself but also what your bank may now check against the register.

What the register is

According to the questions and answers of the register authority (in German, French and Italian), the transparency register is a non-public, centrally kept register. It is run by the Federal Office of Justice. A control office within the Federal Department of Finance checks the entries for accuracy, completeness and currency.

Unlike a commercial register, not everyone can look into it. Access is limited to the control office, the authorities named in the act, financial intermediaries such as banks, and certain advisers who have had due diligence duties under the Anti-Money Laundering Act themselves since 1 October 2026. All of them may use the data only for the tasks the law assigns to them.

Before the launch, the Federal Office of Justice tested the system in a pilot phase in several stages in which, by its own account, around 2,500 companies took part voluntarily. On data protection, the office says that the data are stored only on a physical server in Switzerland, that the system runs in a specially secured network, and that the number of possible queries is limited and protected by multi-factor authentication.

The register rests on self-declaration. The company has to identify, verify and report its beneficial owners itself and keep the entries up to date. Registration is free and usually runs through the federal authorities' platform EasyGov. Reminders, formal requests and extracts, on the other hand, are charged.

Who has to report

The usual Swiss company forms are covered:

• companies limited by shares (AG) and partnerships limited by shares
• limited liability companies (GmbH)
• cooperatives
• investment companies with variable or fixed capital and limited partnerships for collective investment schemes

For readers whose company sits outside Switzerland, the second part matters more. Legal entities under foreign law must report too if they have a branch entered in the Swiss commercial register, if their effective management is in Switzerland, or if they own or acquire real estate in Switzerland. Effective management in Switzerland means, in the authority's reading, that the company is liable to tax in Switzerland under Article 50 of the Federal Act on Direct Federal Taxation.

Exempt are listed companies and their subsidiaries held more than 75 percent by them, pension institutions, and companies at least 75 percent owned by the public sector. Foundations are not covered by the act, but they can be part of the chain of control of a company that is.

Who counts as a beneficial owner

What is reported is always natural persons, human beings, never other companies. A beneficial owner is anyone who ultimately holds at least 25 percent of the capital or the voting rights, directly or through intermediate companies, alone or together with others. Anyone who controls the company in another way, for instance through contracts, counts as well, even without a significant stake.

If there is no such person, the most senior member of the management body is reported as the beneficial owner instead. This substitute rule only applies when nobody actually reaches the thresholds. It does not help a company that simply cannot or will not identify its owners.

For owners who do not live in Switzerland, one detail matters in practice. The register checks the identity of the people reported automatically against the Swiss old-age insurance register. Anyone not recorded there, because they neither live nor work in Switzerland, is checked by means of a copy of their passport or identity card. Without it, the company can receive a request for correction, which is charged.

Which deadlines run

The deadlines depend on the type of company and began to run on 1 October 2026. The authority summarises them like this:

The rule: one month after the next commercial register change. If anything in a Swiss company's commercial register entry changes after 1 October 2026, for example on the board, in the company name or at the registered office, the filing must follow within one month of publication in the Swiss Official Gazette of Commerce.

Maximum deadlines if nothing changes:

• 3 months for companies limited by shares subject to an ordinary audit
• 4 months for other companies subject to an ordinary audit
• 5 months for companies limited by shares without an ordinary audit, so by 1 March 2027
• 6 months for other companies without an ordinary audit and for other legal entities, so by 1 April 2027

Two years if all beneficial owners are already entered in the commercial register as members or officers. A GmbH whose members are all natural persons can, under certain conditions, use a simplified procedure that takes the data over from the commercial register.

Foreign companies have six months from entry into force under Article 53 of the act, so until 1 April 2027. Independently of that, since 1 October 2026 a foreign company can only have a Swiss property purchase entered in the land register if it is already entered in the transparency register.

Anyone who intentionally breaches the reporting or information duties or gives false information can, under Article 43 of the act, be fined up to CHF 500,000. Disregarding a final decision of the control office risks up to CHF 100,000.

What the bank does with the register

For account holders this is the genuinely new part. Under Article 27 of the act, banks and other financial intermediaries may query the register online to the extent they need the data for their due diligence under the Anti-Money Laundering Act. Every such query is logged.

From this follows a duty that did not exist before: reporting discrepancies under Article 30. If a bank finds that the register shows something different from its own records, and this raises doubts about the accuracy, completeness or currency of the entry, it must report it to the register. Before that, however, it has to tell you as the customer and give you a reasonable period to resolve the discrepancy, in particular by filing a correction with the register. If the discrepancy remains, the bank reports within 30 days. Whoever reports in good faith is not liable for it.

This part is not fully in operation yet. In its notice on the launch, the Federal Office of Justice writes that the full register query and the discrepancy report will only be possible at a later date, to spare the register's capacity in the first months. The duty is in the act, though, and once the function is switched on, any difference between your bank file and your register entry becomes a case.

Why Switzerland is doing this now

The Federal Council is open about the timing. It deliberately set entry into force for 1 October 2026 so that the effectiveness of the measures can be assessed in the next FATF country evaluation in 2027 and 2028. That is what the press release of 12 June 2026 says.

The national risk report of 14 October 2026 supplies the background. Switzerland's risk exposure is described as stable; the greatest threat comes from organised crime, corruption and financial and tax crime, often with an international dimension. The report sees particularly high risks in sectors with strong foreign links, with widespread new technologies and in areas regulated only recently. How strongly such country evaluations reach everyday banking is shown by the grey list case described in the FATF removing Monaco and Bulgaria from its grey list.

What to do now

If you hold a Swiss AG or GmbH: check which deadline applies to your company and plan the filing before the next commercial register change. Collect the identity document copies of all beneficial owners who are not in the Swiss old-age insurance register. Make the filing only through EasyGov; the register itself points out that paid offers to carry out the registration are not federal bodies.

If your company sits abroad but has a Swiss connection: a branch, effective management in Switzerland or Swiss real estate triggers the duty. The deadline ends on 1 April 2027; for a property purchase, registration is already a precondition today.

If you run or want to open a business account in Switzerland: make sure the data on the beneficial owners in your bank file, in the commercial register and in the transparency register match. The bank has to establish the beneficial owners under the Anti-Money Laundering Act anyway; in future it can check your information against the register. What Swiss banks ask of non-residents today is covered in a Swiss bank account as a non-resident, and why business accounts for foreign companies are harder in a business account for a foreign company.

If you have a private account in Switzerland: the register changes nothing for you directly, because it records companies, not private persons as account holders. The direction is nevertheless the same as in the new EU customer due diligence standards described in opening an account from July 2027: who stands behind an account should be clear and verifiable for banks and authorities.

Transparency is no obstacle to a Swiss account

For honest account holders the new register is mainly a matter of order. Holding an account in Switzerland is legal, and so is holding a company there. The income remains taxable in your country of residence and is declared there. Anyone who documents their structure cleanly, meets the deadlines and makes sure that every register shows the same thing still has, in Switzerland, one of the most stable financial centres in the world. An overview of accounts there is on our page Open a Swiss bank account. If you want to work out which account and which structure fit your situation, describe it to us in the free consultation.