Associations and Foundations in the Transparency Register
Associations and foundations under Swiss law are not required to report—the law provides an exhaustive list of the legal entities subject to reporting, and they are not included on that list. However, they are not entirely exempt: as soon as your association or foundation controls a public limited company (AG) or a limited liability company (GmbH), a separate reporting obligation arises, and failure to comply is punishable by law.
In a nutshell
- You are required to report it yourself
- No
- Basis
- Art. 2 TJPG, exhaustive
- As a party
- Yes, Art. 13 TJPG
- Deadline for this
- 1 month from the inspection
- Foreign connection
- Can be entered directly
- Deadline then
- 6 months
- Penalty
- Up to CHF 500,000
- AMLA Obligations
- Remain unchanged
Why Associations and Foundations Are Not Included
Art. 2(1)(a) of the TJPG provides an exhaustive list of the entities subject to its provisions: public limited companies, limited partnership with share capital, limited liability companies, cooperatives, investment companies with variable capital, investment companies with fixed capital, and limited partnerships for collective investment schemes. Associations under Art. 60 et seq. of the Swiss Civil Code (ZGB) and foundations under Art. 80 et seq. of the Swiss Civil Code (ZGB) are not included on this list.
This list is exhaustive, not illustrative. There is no catch-all provision that includes other legal forms under Swiss law.
Not subject to reporting requirements—regardless of whether it is entered in the Commercial Register, operates a commercial business, or is subject to an audit requirement.
Not subject to reporting requirements—including charitable foundations as well as family, employee pension, and corporate foundations under Swiss law.
Also not included on the list are sole proprietorships, general partnerships, limited partnerships, and unincorporated partnerships. Please note regarding the names: The limited stock partnership and the limited partnership for collective investment schemes are expressly included.
Are you unsure whether your legal form is truly exempt? The detailed TJPG check clarifies this and provides a reasoned explanation of the result. A documented “not affected” status is valuable if a bank, an auditor, or the supervisory authority asks for it.
Three cases where you are, in fact, affected
The exemption applies to reporting on your own organization. It says nothing about what obligations arise if your association or foundation has interests elsewhere or has a foreign connection.
- You hold an interest in a public limited company (AG), a limited liability company (GmbH), or a cooperative. In that case, as a shareholder, you are subject to the reporting requirement under Art. 13 TJPG—to the company, not to the registry. It is not the foundation that is reported, but the natural persons behind it.
- You exercise control over a company in another way—even without a stake: Anyone who exercises control through provisions in the articles of incorporation, a right of appointment, or an agreement falls under Art. 14 TJPG and must report this to the company themselves.
- Your organization is governed by foreign law. In that case, it may be directly subject to the reporting requirement—with a six-month deadline and a list to be kept at the place of actual administration.
Who is considered the beneficial owner of a foundation?
If a legal entity subject to reporting requirements is controlled by a foundation under Swiss law, Art. 7 TJPV determines who is considered its beneficial owners. The provision deviates from the general concept of control and uses roles rather than thresholds.
The decisive factor is who actually established the foundation—not who is formally listed as the founder in the foundation deed.
All persons named in the foundation deed or in the bylaws.
If beneficiaries are defined only by category, the group must be specified as such.
All other persons who have the right to designate or appoint representatives of the foundation, provided that such representatives have the authority to dispose of the foundation’s assets, or who have the right to change the allocation of assets or the appointment of beneficiaries.
If one of these roles is held by a legal entity—for example, if a company is designated as a beneficiary—then, pursuant to Art. 7(2) TJPV, that entity’s beneficial owners are considered beneficial owners. The review therefore proceeds to the next level.
A foundation in the chain of ownership makes the investigation complex, but not impossible. The tool maps out foundations and their roles and compiles the list that the participating company needs.
Launch the management toolWho is considered the beneficial owner in the case of an association?
For an association, the rule is much simpler. According to Art. 8(1) TJPV, a beneficial owner is any natural person who ultimately and effectively controls the association’s decisions. If no one meets this criterion, the highest-ranking member of the governing body is deemed the beneficial owner by default under paragraph 2.
An association with numerous members and a board of directors elected by the general assembly has no one who ultimately exercises actual control over its decisions. In that case, the substitute rule applies, and the presidency is registered.
The situation is different if one person effectively determines the decisions—for example, in an association with few members where one person is both the primary financial contributor and the president. The actual situation, not the formal one, is decisive.
The criterion “ultimately and effectively controlled” is deliberately formulated in broad terms and is not tied to voting shares or capital shares. Associations have neither capital nor graduated voting rights; therefore, the circumstances of each individual case are decisive. Anyone applying the substitute rule should document this assessment—not just its result.
What deadlines apply to you
Since you generally do not file a report yourself, your deadlines depend on your role.
| Your role | What to Do | Deadline |
|---|---|---|
| Neither involved nor related to foreign entities | Nothing. However, the result of the review should still be documented. | — |
| Holder of shares constituting a controlling interest | Reporting of beneficial owners to the company (Art. 13 TJPG) | 1 month from the date control is established; changes must also be reported within 1 month |
| Control exercised in another manner or through a chain of control | Report directly to the company (Art. 14 TJPG) | 1 month; changes also 1 month |
| At the company’s request | Submission of information and supporting documents for review (Art. 13(4) TJPG) | Art. 13(4) TJPG does not specify a deadline; for information reported under the previous law, a one-month period applies pursuant to Art. 49(2) TJPG |
| Legal entity governed by foreign law | Self-reporting to the Transparency Register (Art. 17 TJPG) | 6 months after entry into force, until April 1, 2027 |
The second line refers to the establishment of control, not to a request from the company. For newly acquired equity interests, this clarifies when the one-month period begins.
For existing equity interests, the transitional provision of Art. 49 TJPG applies: Anyone who has complied with the previous reporting obligation under Art. 697j or 790a OR has already fulfilled the obligation under Art. 13(1) TJPG—but only to the extent that the persons reported at that time are still the beneficial owners under the new law. This is not necessarily the case with foundations, because Art. 7 TJPV uses categories rather than thresholds and may therefore result in a different group of individuals than the previous review. Anyone holding a controlling interest should perform this comparison before the company asks.
You can find all deadline schedules, including a calculator and deadline calendar, under “Transparency Register: By When Must You Report?”
Clarify Roles, Document Information
For associations and foundations, the effort lies not in the reporting itself, but in the investigation and verification: Who are the people behind your organization, and how do you verify this to third parties?
- Verify eligibility and document it with justification
- Map the roles of a foundation in accordance with Art. 7 TJPV
- Document the audit of the association
- Document information provided to companies in a verifiable manner
- Monitor monthly deadlines for changes
Details about your case
The sections above cover the standard cases. These points address specific situations.
If your organization is subject to foreign law: Three connecting factors, a six-month deadline—and the land registry entry depends on it.
Here, the initial situation is reversed. Art. 2(1)(b) TJPG subjects legal entities governed by foreign law to Swiss law if one of three conditions is met. The legal form is irrelevant—a foreign foundation or association is covered just as much as a foreign corporation.
| Connecting factor | Consequence |
|---|---|
| A branch office in Switzerland registered in the Commercial Register | Full compliance pursuant to Art. 17 TJPG |
| Actual management in Switzerland | Full tax liability, plus registration requirement under Art. 18 TJPG |
| Ownership of real property in Switzerland or acquisition within the meaning of the Property Tax Act (BewG) | Full registration; without proof of registration, the land registry entry will be suspended |
In practice, the second line applies to most cases. A Liechtenstein foundation whose board of trustees meets in Switzerland and whose business is managed from there has its actual administration in Switzerland. It is therefore subject to the law, must designate a representative or a domicile for service in Switzerland, and must maintain a register of its owners with their names and addresses at the place of actual administration.
Whether a foundation has its actual administration in Switzerland is determined by the definition in Art. 50 of the Federal Act on Direct Federal Tax, to which Art. 24 of the TJPV refers. The decisive factor is therefore the tax law perspective, not the registered office as defined in the articles of incorporation.
With regard to the registration requirement under Art. 18 of the Federal Act on Direct Federal Tax (TJPG), Art. 24(2) of the Federal Ordinance on Direct Federal Tax (TJPV) lists the categories subject to registration—explicitly including foundations in addition to corporations and partnerships. Foreign foundations are thus subject to Art. 2(1)(b) of the TJPG and are also covered by the registration requirement.
What Remains Unchanged for You: Bank clarifications, foundation supervision, and association law remain as they are.
The TJPG establishes a registry. It does not repeal any other transparency obligations, and for associations and foundations, it is precisely these other obligations that have a tangible impact in practice.
The due diligence requirements under the Anti-Money Laundering Act and the banks’ codes of conduct remain in effect. Although Art. 23(2) of the TJPG now allows financial intermediaries to rely on entries in the transparency register, this does not help you because your association or foundation does not appear there at all. Your bank will therefore continue to ask you directly about founders, beneficiaries, and controlling shareholders.
The regulatory obligations of foundations, as well as the association’s financial reporting, membership records, and minute-taking, continue to be governed by the Swiss Civil Code (ZGB) and the relevant special statutes.
Nevertheless, the practical benefit is significant: Once a foundation has clearly documented its roles—actual founder, beneficiaries, and persons with appointment rights—it can use the same list both for reporting under Art. 13 of the Anti-Money Laundering Act (TJPG) and for responding to inquiries from the bank.
Frequently asked questions
Does our association have to file a report with the Transparency Register?
No. Article 2 of the TJPG provides an exhaustive list of the legal entities subject to this requirement, and an association under Article 60 et seq. of the Swiss Civil Code (ZGB) is not included. This applies regardless of whether the association is registered in the Commercial Register or is subject to an audit.
What about a foundation?
No, not a foundation either. A foundation under Articles 80 et seq. of the Swiss Civil Code (ZGB) is not listed in Article 2 of the TJPG and is not subject to the Act. This applies to charitable foundations as well as to family and corporate foundations under Swiss law.
We hold shares in a public limited company (AG). What do we need to do?
If your ownership interest reaches a level that enables ultimate control, you must report the beneficial owners to the company in accordance with Article 13 of the TJPG. The required information includes last name and first name, date of birth, nationality, address, and country of residence, as well as the nature and extent of control, and this must be done within one month of the control arising.
Who is considered the beneficial owner of a foundation?
Pursuant to Article 7 of the TJPV, the actual founder, the specifically named beneficiaries, the beneficiary groups, and all other persons who can appoint representatives of the foundation—provided they have the power to dispose of the foundation’s assets or have the right to change the allocation of assets or the appointment of beneficiaries—must be reported. There is no order of priority: all of these persons must be reported.
Who is considered the beneficial owner in the case of an association?
According to Article 8 of the TJPV, any natural person who ultimately and effectively controls the association’s decisions. If no one meets this criterion, the highest-ranking member of the governing body applies by default. This is typically the case for associations with many members and a duly elected board of directors.
Does this also apply to a Liechtenstein foundation?
If its actual administration is located in Switzerland, it has a branch office registered in the Commercial Register, or it owns real property in Switzerland, it is directly subject to the law. In that case, the obligations under Article 17 of the TJPG apply; in addition, a register of owners must be maintained at the place of actual administration, and the notification must be filed within six months of the law’s entry into force.
Will anything change regarding our banking relationship?
Not as a result of the TJPG. Banks’ due diligence obligations are based on the Anti-Money Laundering Act and the banks’ codes of conduct and remain unchanged. Your bank will therefore continue to ask about founders, beneficiaries, and controlling owners, even if you yourself are not required to file a report with the transparency register.
What are the consequences if we do not provide the information?
Anyone who intentionally violates the reporting obligation under Articles 13, 14, or 17 of the TJPG is subject to a fine of up to 500,000 Swiss francs under Article 43 of the TJPG. In addition, under Article 38(2) of the TJPG, the supervisory authority may suspend the rights of participation and property rights in the relevant company.
Has your question been answered? Then record your organization’s roles in the management tool.
Launch the management toolLegal Basis and Further Resources
- Federal Act of September 26, 2025, on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG, SR 955.3)
- Ordinance of June 12, 2026, on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPV, SR 955.31)
- Civil Code: Associations (Art. 60 et seq. ZGB) and Foundations (Art. 80 et seq. ZGB)
- More on this site: Corporation · Limited Liability Company · Cooperative · Sole Proprietorship · Branch Office · Frequently Asked Questions
Last updated: September 16, 2026.
Clarify your role before anyone asks
Whether your association or foundation is required to report depends on its ownership structure and foreign ties—not on its legal form alone. We review both factors and document the results in a way that stands up to scrutiny.