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Prepare your transparency register report
Since 1 October 2026, the Transparency Act (TJPG) has required almost all Swiss stock corporations, limited liability companies and cooperatives to report their beneficial owners to the federal transparency register. How much time you have depends on your legal form, audit requirement and commercial register entry – the range extends from one month to 30 September 2028.
Transparenzregister.ch is a private service.
Which deadline applies to your company?
The TJPG has no single deadline. Three questions are decisive: Did your company already exist on 1 October 2026? Is it subject to an ordinary audit? And are all beneficial owners already entered in the commercial register?
| Your situation | Deadline | Due date |
|---|---|---|
| AG subject to an ordinary audit | 3 months | 31 December 2026 |
| Other companies subject to an ordinary audit | 4 months | 31 January 2027 |
| AG without an ordinary audit | 5 months | 28 February 2027 |
| Other companies and legal entities | 6 months | 31 March 2027 |
| Foreign companies with a Swiss connection | 6 months | 31 March 2027 |
| All beneficial owners are already entered in the commercial register as shareholders or members of a governing body | 2 years | 30 September 2028 |
The staggered deadlines are set out in Art. 51 para. 3 TJPG, the two-year period in para. 2, and the deadline for foreign legal entities in Art. 53. The fourth row is abbreviated: there, the law refers to “other companies that do not meet the requirements for a limited audit, and other legal entities”.
The Express Check
Answer a few simple questions about your company. You will immediately receive an assessment, including the deadline and next steps.
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The detailed check also identifies the beneficial owners, assesses the reporting procedure and provides a checklist of the required information.
Detailed check · CHF 49 incl. VATEnter your ownership structure and receive the beneficial owners as a dated PDF, as the basis for your report.
Identify beneficial owners · CHF 49 incl. VATWhat is the transparency register – and what is the TJPG?
The TJPG is the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners. It creates a central, government-run register that records which natural persons actually control a Swiss company.
Until now, companies had to keep their own register of beneficial owners (Art. 697j and 790a CO). This decentralised solution was replaced when the TJPG entered into force on 1 October 2026. The register is kept by the Federal Office of Justice. Reports are filed via the electronic platform of the Confederation or, if a commercial register transaction is pending anyway and all beneficial owners are entered there, via the cantonal commercial register office (Art. 11 TJPG).
The background is international: with the TJPG, Switzerland implements key recommendations of the Financial Action Task Force, making money laundering, terrorist financing and the circumvention of sanctions more difficult.
AGs, limited partnerships with share capital, GmbHs, cooperatives, SICAVs, SICAFs and limited partnerships for collective investment (LPCI), as well as certain foreign entities with a Swiss connection.
Surname and first names, date of birth, nationalities, municipality, postcode and country of residence, and the nature and extent of control. The full address is obtained but not reported.
The control office, the authorities named in the law, and financial intermediaries and advisers – and only insofar as necessary for their tasks. The register is not public.
General rule: one month. For existing companies, staggered transition periods of between three months and two years.
Who has to report – and who does not?
Subject to reporting
Foreign companies
Companies with their registered office abroad also become subject to the reporting obligation if one of the following conditions is met: a branch office in Switzerland entered in the commercial register, effective management in Switzerland, or the ownership or acquisition of real estate in Switzerland. Details under Branch offices of foreign companies.
It is not only the company that has obligations
Holders of company shares, the beneficial owners themselves and third parties in the chain of control must also provide information and cooperate. Responsibility for the report lies with the highest-ranking member of the managing body – the execution may be delegated, the responsibility may not. More under Responsibility of the board of directors.
Who counts as a beneficial owner?
A beneficial owner is any natural person who ultimately controls a company. The TJPG provides for three ways in which this can be the case.
The 25 percent threshold
Anyone who, directly or indirectly, alone or acting in concert with third parties, holds at least 25 percent of the capital or voting rights is deemed to be a beneficial owner. For the extent, the band is sufficient – 25 to 50, over 50 to 75 or over 75 percent; the law does not require an exact percentage.
Control in some other way
This covers anyone who can appoint or remove more than half of the members of the management or administrative body, has a veto over decisions on purpose, management, strategy, budget, investment planning or financing, or can bring about decisions on profit distributions. Such control is exercised through agreements with shareholders, options and convertible bonds, provisions in the articles of association, agency and fiduciary relationships, or relationships between related persons (Art. 3 TJPV). This criterion is the one most frequently overlooked.
Substitute rule
If no person can be identified under the first two criteria, the highest-ranking member of the managing body is deemed to be the beneficial owner.
Multi-tier holdings
In multi-tier structures, the chain must be traced back to the natural person. An indirect holding establishes control if it comprises more than 50 percent of the intermediate legal entity and that entity in turn holds at least 25 percent of your company (Art. 2 TJPV). The percentages are not multiplied.
For the extent to be reported, what counts is the holding held directly in your company. If someone holds 100 percent of a holding company and the holding company holds 51 percent of your company, that person is a beneficial owner with an extent of over 50 to 75 percent. More under Holding company.
Identifying beneficial owners is the most demanding step
Record the structure once, have the beneficial owners identified under the TJPV, monitor deadlines – for one company or an entire portfolio of client companies.
- Record the ownership structure once, use it many times
- Check all four TJPV control categories individually
- Collect information and supporting documents for each person in a structured way
- Monitor deadlines for each company
- Keep verifiable documentation
After the initial report: reporting changes on an ongoing basis
Reporting is not a one-off matter. Any change to a registered fact must be reported within one month, calculated from the time the company becomes aware of it (Art. 10 TJPG). For many companies, this is the more time-consuming part.
Sale of shares or inheritance that takes a holding above or below a threshold. Restructuring in the chain of control. Control in some other way that arises or ceases. Change of the municipality of residence of a reported person.
Changes in holdings within the same band. Likewise, changes to company name, legal form or registered office from the commercial register, which the register takes over itself.
Information and supporting documents for ten years after a person has ceased to be a beneficial owner. In addition, the register kept under the previous law for ten years from entry into force, i.e. until 30 September 2036.
Because every change in the commercial register can trigger a one-month deadline, it is advisable to keep track of changes on an ongoing basis. All triggers in detail and the required evidence.
The software for preparing your TJPG report
The effort usually lies not in the report itself, but in the identification that precedes it. This requires a clean ownership structure, a sound assessment of the control relationships and complete personal information. The Management tool guides you through exactly these steps and documents the result in a traceable way. The report itself is free of charge via the electronic platform of the Confederation.
- Record the structure You enter shareholders, capital and voting rights. For multi-tier structures, you map the chain of holdings.
- Identify beneficial owners The software applies the TJPG and TJPV criteria to your structure and proposes the persons to be reported, including under the substitute rule.
- Check completeness Missing information, implausible ownership ratios and open control questions are flagged before you submit.
- Submit and keep up to date You receive all the information for your report, together with documentation for your records; after that, the tool monitors the deadlines.
For advisers managing multiple clients
If you look after several companies, you manage all client companies on one platform: deadlines per legal entity, status of reports and alerts on commercial register changes. More under For advisers.
What happens if a report is late or incorrect?
Maximum fine for intentional breach of the reporting obligations or for providing false information to the control office (Art. 43 TJPG). The basic offence requires intent.
Maximum fine for intentionally disregarding a final and binding decision of the control office issued with reference to the threat of penalty (Art. 44 TJPG).
In the event of repeated breaches, the control office may suspend the participation and property rights of the shareholders concerned (Art. 38 TJPG).
The prosecuting and adjudicating authority is the Federal Department of Finance (Art. 45 TJPG). These are maximum amounts, not flat rates. All consequences in detail.
Frequently asked questions about the transparency register
Is transparenzregister.ch the official website?
No. transparenzregister.ch is an independent, private information and support service provided by Buchhaltungsabo GmbH. We are not a public authority and do not run the federal transparency register. The official information is available at transpareg.admin.ch. Our services are voluntary and are not a prerequisite for filing the report.
Who has to register in the transparency register?
The law covers stock corporations (AG), limited partnerships with share capital, limited liability companies (GmbH), cooperatives, SICAVs, SICAFs and limited partnerships for collective investment (LPCI). In addition, it covers legal entities under foreign law with a branch office entered in the commercial register, with effective management in Switzerland or with real estate in Switzerland. Sole proprietorships, partnerships, associations and foundations fall outside the scope of the law. Also exempt are listed legal entities and their subsidiaries held by more than 75 percent, occupational pension institutions, and legal entities in which public bodies hold at least 75 percent.
By when do I have to report?
The general rule is a deadline of one month. For companies that already existed on 1 October 2026, staggered transition periods apply: three months for AGs subject to an ordinary audit, four months for other companies subject to an ordinary audit, five months for AGs without an ordinary audit, and six months for all others and for foreign companies. If all beneficial owners are already entered in the commercial register, the deadline is extended to 30 September 2028.
What happens if my commercial register entry changes?
Any change to the commercial register entry after 1 October 2026 triggers a reporting deadline of one month. This deadline takes precedence over all longer transition periods – including the two-year period.
Who counts as a beneficial owner?
Any natural person who holds at least 25 percent of the capital or votes – directly, indirectly or acting in concert – or who controls the company in some other way. If no such person can be identified, the highest-ranking member of the managing body is deemed to be the beneficial owner.
Can I carry over my existing register under Art. 697j CO?
Not without reviewing it. The definition in the TJPG differs from that in the Code of Obligations, so the assessment must be made according to the new criteria. For shareholders of an AG or GmbH who have fulfilled their reporting obligation under Art. 697j and 790a CO, that obligation is deemed to have been met – but only insofar as the persons reported at the time are also the beneficial owners under the new law (Art. 49 TJPG). Missing information must be provided within one month upon request.
Does this also apply to a small GmbH with two shareholders?
Yes. The law has no size threshold – neither for turnover, nor for capital, nor for the number of persons involved. The legal form alone is decisive. A GmbH with two shareholders is just as subject to the reporting obligation as a group of companies. In such cases, however, the report is usually completed quickly because the structure is straightforward.
Two shareholders each hold 50 percent – who is the beneficial owner?
Both. Every natural person with at least 25 percent is a beneficial owner, not just the person with the largest stake. With two persons each holding 50 percent, both must therefore be reported, each with an extent in the band of at least 25 to at most 50 percent.
Does the capital count, or the voting rights?
To determine whether someone is a beneficial owner, either one is sufficient: at least 25 percent of the capital or of the votes. For stating the extent, the capital holding generally applies – only if the voting rights lead to a higher band is that band decisive. An exact percentage is not required; the band is sufficient: 25 to 50, over 50 to 75 or over 75 percent.
What applies in the case of a shareholders’ agreement?
Anyone who coordinates their conduct in exercising control with third parties is acting in concert. The holdings are then considered together rather than individually – four shareholders each holding 10 percent who are contractually bound together exceed the threshold jointly. The identity of each person is nevertheless recorded individually. Agreements with shareholders, options, convertible bonds or provisions in the articles of association can also establish control in some other way.
Does this also apply to a holding company or a company without operating activities?
Yes. Whether an AG or GmbH is operationally active makes no difference – a pure holding, real estate or investment company is also subject to the reporting obligation as long as it is entered in the commercial register. In addition, in holding structures the chain must be traced back to the natural person: a company as the shareholder is never a sufficient answer.
What applies to a company in liquidation?
The reporting obligation remains in place as long as the company is entered in the commercial register. If a subsidiary report is required because no one meets the criteria for beneficial ownership, in a liquidation the liquidator takes the place of the highest-ranking member of the managing body.
Who is liable if the report is incorrect or incomplete?
Responsibility lies with the highest-ranking member of the managing body – in an AG, usually the chair of the board of directors; in a GmbH, the person chairing the management. The task may be delegated to employees or to third parties, but responsibility for its proper performance remains (Art. 12 TJPG).
What should I do if a shareholder refuses to provide information?
In that case, this circumstance itself must be reported – with all available relevant information, including details of the chain of control and of those shareholders who have not complied with their disclosure obligations. In addition, the highest-ranking member of the managing body is reported as the contact person. Silence is not an option: reporting that the beneficial owner could not be identified is also an obligation with a deadline.
How long do we have to keep the records?
Ten years after the person concerned has ceased to be a beneficial owner. It must also be documented how a person was identified and how this status was verified – and, if this was not possible, which steps were taken to do so (Art. 8 TJPG).
Is the transparency register open to the public?
No. Access is restricted to authorities, financial intermediaries and advisers under the Anti-Money Laundering Act (AMLA) – and only insofar as they need the data to fulfil their obligations. Competitors, business partners and the general public have no access.
Do you know which deadline applies to your company?
The Express Check takes one minute, is free of charge and requires no registration. Afterwards, you will have an initial assessment of whether you are affected and which deadline framework applies.