1. Overview and participants
The consultation on the TJPV (and on the amendments to the AMLO/AMLO-FINMA) ran from 15 October 2025 to 30 January 2026. Around 80 statements were submitted – by cantons, political parties, business associations, lawyers’ and notaries’ organisations, financial intermediaries and other interest groups. The subject of the consultation is the Transparency Register Ordinance (TJPV); the FDF explanations explain how it is to be applied.
2. General position of the statements
Many consultation participants welcome the Transparency Register as an important step in combating money laundering. At the same time, criticism has been raised that the administrative burden for SMEs is considerable and that the implementation deadlines are tight.
Several associations are calling for longer transitional periods and clearer exemption rules for micro-enterprises.
3. Definition of the beneficial owner
The definition was broadly accepted, although representatives from the business community are calling for clearer criteria to distinguish complex holding structures.
4. Thresholds (25/50/75%)
The thresholds of 25% for direct control and more than 50% for indirect control are common internationally. Some statements called for a reduction to 10% (rejected) or an increase to 33% (also rejected).
5. Control chain and trusts
The rules on trusts and multi-level control chains were considered complex but necessary. Requests for additional explanations were partially taken into account.
6. Reporting procedure
Reporting via the electronic platform of the Confederation was generally welcomed. Criticism focused on the requirement for authorisation and the requirements for electronic signatures.
7. Role of the commercial register offices
Several cantons and the SOGC editorial office are calling for greater involvement of the commercial register offices as receiving offices. The ordinance takes this into account to some extent.
8. Access and data protection
The restriction of access to authorised authorities and financial intermediaries is welcomed. Requests for public access (as in the EU) were rejected.
9. Control office
The creation of a control office within the FDF is supported. Its independence and resource allocation were discussed.
10. Fees
The fact that the initial report is free of charge was welcomed. Some respondents criticised the price of CHF 40 for an extract as too high.
11. Amendments to the AMLA and AMLO
Making advisors (lawyers, notaries, fiduciaries) subject to due diligence obligations was the most widely discussed point. Lawyers’ associations warned against restricting professional secrecy.
12. Conclusion and outlook
The Federal Council has made various adjustments – in particular to the transitional periods and the simplified procedure. The TJPV entered into force on 1 October 2026.