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Legal Form of a Cooperative

Transparency Register for Cooperatives

Cooperatives are subject to the same reporting requirements as AGs and GmbHs—but the review almost always yields a different result. Because each member has exactly one vote and a minimum of seven members is required, no single member can reach the 25 percent threshold through their votes alone. Therefore, the highest-ranking member of the governing body is generally reported—unless several members act in concert.

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Your Cooperative at a Glance

Subject to Reporting Requirements: Yes, with a few exceptions
Voting rights threshold: Practically unachievable
Capital threshold: Only for share certificates
Standard case: The substitute rule applies
Must be reported: Usually the chair of the administration
Frequent deadline: 2 years, until October 1, 2028
Otherwise: 4 or 6 months
Simplified procedure: Not provided for

Is your cooperative affected?

The cooperative is included in the list of legal entities subject to the law (Art. 2, para. 1, letter a, item 4 TJPG). Neither nonprofit status nor a self-help purpose provides an exemption: A housing cooperative with twenty apartments is subject to the law just as much as a shopping or agricultural cooperative.

Covered

Every cooperative under Swiss law—housing, agricultural, purchasing, and service cooperatives, as well as cooperative associations.

Pension provision (Art. 3(b))

Occupational pension plans and institutions serving pension purposes that are supervised under Articles 61 and 64a of the Occupational Pensions Act (BVG) are excluded. This applies to cooperatives because a cooperative is a permissible legal form for pension plans.

Public entities (Art. 3(c))

Excluded are legal entities in which at least 75 percent of the ownership interests are held, directly or indirectly, by public entities. A minority ownership interest held by a municipality is not sufficient.

The third exception is the most important one in practice for housing cooperatives. It is based on ownership interests, not on subsidies, building lease agreements, or service agreements. Therefore, entities that receive public funds are not automatically exempt.

Unsure which scenario applies to you? The detailed TJPG Check evaluates the grounds for exemption based on your specific circumstances and documents the result with justification—even a “not applicable” finding must be substantiated if the regulatory authority requests it.

Who is the beneficial owner of a cooperative?

A beneficial owner is any natural person who ultimately controls the legal entity by holding, directly or indirectly, alone or in concert with third parties, at least 25 percent of the capital or voting rights, or who controls it in any other way (Art. 4(1) TJPG). The definition is the same for all legal forms—in the case of a cooperative, it simply leads to a different result.

Three Exceptions to This Calculation

Joint Agreement. If several members coordinate their actions, the threshold applies to the total jointly held amount (Art. 13(2) TJPV). In a cooperative with seven members, two people are sufficient for this; in one with twelve members, three are required. This is the most realistic way for a cooperative to have a beneficial owner after all.

Cooperative Association. An association consists of at least three cooperatives (Art. 921 OR). With three members, each holds approximately 33 percent of the votes—thus exceeding the threshold. Because the members are legal entities, the chain of control must be traced further; if it does not end with a natural person, the substitute rule applies again.

Fewer than four members. Mathematically, the threshold would then be met. At the same time, there is an organizational deficiency to which the provisions of stock corporation law apply mutatis mutandis (Art. 831(2) CO). The reporting obligation under the TJPG remains unchanged in this situation.

If the capital and control remain in other ways

This shifts the focus of the review to two areas that are often overlooked in the context of cooperatives.

Equity Participation, Art. 1 TJPV

If your cooperative issues share certificates, a member may hold multiple certificates. If the share of the cooperative’s capital exceeds 25 percent, that person is the beneficial owner—regardless of the fact that they have only one vote. Cooperatives without share certificates do not have cooperative capital; this assessment does not apply to them.

Indirect Participation, Art. 2 TJPV

More than 50 percent in an intermediate legal entity that, in turn, holds at least 25 percent of the cooperative’s capital. Relevant when share certificates are held by corporations.

Joint Arrangement, Art. 4 TJPV

Any party that coordinates its conduct with third parties to exercise control. Because the threshold for joint action applies to the total jointly held interest (Art. 13(2) TJPV), a group acting in concert can reach both the capital and voting thresholds, even though none of its members reaches them individually. For small cooperatives, this is by far the most important point to consider in practice.

Control by Other Means, Art. 3 TJPV

This includes anyone who has the right or the actual ability to appoint or remove more than half of the members of the management or administrative body; to exercise a veto on resolutions concerning changes to the purpose, the election of management, changes to and expansions of the corporate strategy, budgets, and investment planning, or financing through equity and debt capital; or to bring about decisions that result in profit distributions or other dispositions of assets. In the case of cooperatives, this typically occurs through provisions in the bylaws, through a local government’s or umbrella organization’s right of representation on the board, or through relationships between related parties.

The categories must be reviewed individually, not as a cascade. Unlike under the Anti-Money Laundering Act, the review does not end with the first match.
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The Standard Case: The Substitute Rule

If no one meets the criteria of Art. 4(1) TJPG, the highest-ranking member of the governing body is deemed to be the beneficial owner on a subsidiary basis (Art. 4(2) TJPG). In the case of a cooperative, this is the norm, not the exception.

Who counts as the most senior member of the governing body under Art. 20 para. 3 TJPV

Situation Must be reported

Separate management body in place The Chairperson of the Executive Board

No separate management body The President of the Administration

Liquidation The liquidator

Staying of Enforcement Proceedings The Trustee

The ordinance explicitly mentions in the second line the chairperson of “the board of directors or the administration”—the administration is the governing body of the cooperative (Art. 894 et seq. CO). For the typical cooperative without its own executive management, it is thus clear who must be reported.

If several persons hold the position simultaneously, all of them must be reported in accordance with Art. 20(4) TJPV. This is relevant for cooperatives where the administration operates collegially without a designated chairperson. In addition, the position within the cooperative must be specified in every case (Art. 20(2) TJPV).

The substitute rule is not a free pass

It applies only after an examination of all four control categories has yielded no results—and this examination must be documented. Anyone who directly reports the executive committee without having examined capital shares and control in other ways does not comply with Art. 7 TJPG, even if the result happens to be correct in the end.

Deadlines for the Cooperative

The law takes effect on October 1, 2026. The applicable deadline depends on who is ultimately reported as the beneficial owner in your organization.

If the substitute rule applies, the deadline is two years

If all beneficial owners are registered in the Commercial Register as members or as officers, a two-year period applies pursuant to Art. 51(2) TJPG—that is, until October 1, 2028. If, under the substitute rule, the chair of the board of directors is reported and that person is registered as an officer, the requirement is met. For the vast majority of cooperatives, this is the applicable scenario.

If, on the other hand, a member reaches the capital threshold through share certificates, that member is not listed in the Commercial Register—cooperative members are not registered there. In that case, the shorter deadlines apply.

Deadlines under Art. 9, 10 and 51 TJPG

Situation Deadline Reference Date

All beneficial owners are registered in the Commercial Register as shareholders or as members of the governing body 2 years after entry into force 1 October 2028

Other cooperatives subject to mandatory regular audits, classified as “other companies” 4 months after entry into force February 1, 2027

Other cooperatives that do not meet the requirements for a limited audit 6 months after entry into force April 1, 2027

First amendment to the commercial register entry after entry into force—if earlier 1 month from this entry Ongoing

Cooperative to be newly established after October 1, 2026 1 month from entry in the commercial register Ongoing

Change to a fact entered in the Transparency Register 1 month from the date of becoming aware Ongoing

Two outstanding issues in the wording

Art. 51(3) TJPG lists four categories of cases. Two of these are expressly tailored to stock corporations; one covers “other companies” subject to mandatory regular audits (four months); and the last covers “other companies that do not meet the requirements for a limited audit” as well as “other legal entities” (six months).

This raises two questions for the cooperative. First, it is unclear whether it qualifies as an “other company”—the Swiss Code of Obligations systematically contrasts cooperatives with commercial companies—or as “other legal entities”; in the latter case, the six-month deadline would apply regardless of the type of audit. Second, according to the wording, a cooperative subject to a limited audit does not fall into either of these two categories.

Until this is clarified, the shorter deadline is the safer option. In most cases, the question is moot anyway because the two-year rule applies.

The most important practical point is found in Art. 51(1) TJPG: As soon as a change is entered in the commercial register after the law takes effect—a change in management, a new address, an amendment to the articles of association—a one-month period begins to run from the date of that entry. For cooperatives, this is not merely a theoretical consideration: Every change in management triggers an entry in the commercial register and can shorten the two-year period to just a few weeks. By contrast, the mere reelection of the same individuals does not change the entry.

In the event of such a change, the cantonal commercial registry offices draw attention to the reporting requirement (Art. 52(1) TJPG). After the one-month period has expired—but no earlier than six months after the change takes effect—the registry authority reviews on its own initiative whether a report has been filed (Art. 52(2) TJPG).

Not every change is subject to mandatory reporting

A change in shareholding must be reported only if it causes the shareholding to exceed or fall below a threshold (Art. 39(3) TJPV). The reporting requirement does not apply at all to changes in the company name, legal form, registered office, and ZIP code of the domicile address in the Commercial Register, nor to name changes resulting from a change in civil status—the registry authority updates this information itself (Art. 39(4) and Art. 40 TJPV).

If, however, the reporting is done in accordance with the substitute rule, any change in the executive committee constitutes a change to a registered fact and must be reported within one month. For cooperatives with frequent changes in leadership, this is the actual ongoing task.

You can find all deadline schedules, including a calculator and deadline calendar, under “Transparency Register: Deadlines—By When Must You Report?”

A change in the executive committee constitutes a reportable event for your organization. The tool detects when a Commercial Register entry brings the deadline forward or when a reported position changes.
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The review is straightforward, but the documentation is not

For a cooperative, the initial filing is quick to complete. The effort lies in the documentation and ongoing updates: The audit must be documented, and every change in the executive board triggers a filing.

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Record the membership and share certificate structure
Verify all four control categories in a traceable manner
Document the results with justification, even when applying the fallback rule
Document supporting evidence and audit steps for ten years
Monitor changes in leadership and monthly deadlines

Details about your case

The sections above cover the standard case. These points address specific scenarios and obligations in the process.

Typical Scenarios: Eight Initial Situations and Who Is Reported in Each.

Allocation of beneficial owners by starting situation

Starting situation Beneficial owner What to Keep in Mind

Housing cooperative, 80 members, equal shares The Chair of the Board of Directors, in a subsidiary capacity Neither the voting threshold nor the capital threshold was met. The review must nevertheless be documented.

Cooperative without share certificates The Chair of the Board of Directors, in a subsidiary capacity In the absence of cooperative capital, the capital audit is entirely waived; only the method of verification by other means remains to be clarified.

One member holds 40% of the share capital This member The capital threshold has been reached, even though the person has only one vote. The range reported is 25 to 50 percent.

Shares are held by a corporation; one person owns 100% of this corporation This person, provided that the corporation holds at least 25% of the capital Indirect control. The public limited company’s stake in your cooperative is reported as the scope of control.

The bylaws grant an umbrella organization the right to appoint a majority of the board of directors Review of the chain of control behind the umbrella organization Verification by other means. If the chain does not lead to a natural person, the default rule applies.

The municipality holds a 30% stake and, according to the bylaws, appoints two of the five board members As a general rule, the chair of the board of directors; alternatively The exception does not apply below 75 percent. A municipality is not a natural person, and two out of five seats do not constitute a majority.

Cooperative association with three member cooperatives Review of the chain of control behind each member cooperative Approximately 33% of the votes each exceed the threshold. Because the members are legal entities, the chain must be traced further.

Several members coordinate their actions through a contract The parties involved, when a threshold is reached collectively In the case of a joint agreement, the total jointly held volume counts, not the individual share.

For additional examples of this calculation, see “Who Is the Beneficial Owner?”

What information must be reported: personal data, type of control, threshold range—and what is excluded under the substitute rule.

The ordinance specifies what the cooperative must obtain and report for each beneficial owner (Art. 10 TJPV): last name and first name, date of birth, nationalities, as well as municipality, ZIP code, and country of residence. In addition, information regarding the nature and extent of control must be provided. A complete street address is not submitted to the registry.

You must verify the AHV number in advance

According to Art. 10(2) TJPV, the cooperative must verify whether the person has an AHV number. If they do not have one, a copy of their Swiss or foreign passport, an identity card, or a Swiss foreigner’s identity card must be obtained. Since the chairperson is usually registered with the cooperative, this generally applies to only one person—the effort involved is significantly less than for a public limited company (AG) or a limited liability company (GmbH) with multiple shareholders.

For each beneficial owner, it must be determined whether control is exercised alone or in concert, directly or indirectly, and through a stake or by other means (Art. 12 TJPV). If control is based on a shareholding, the extent must be reported in three ranges (Art. 13 TJPV): at least 25 percent up to a maximum of 50 percent, over 50 percent up to a maximum of 75 percent, and over 75 percent.

If the report is filed under the alternative provision, the details regarding the nature and extent of control are omitted entirely: Art. 20(2) TJPV requires, in addition to the personal data specified in Art. 10, only the function within the legal entity. The case studies from the Department of Finance illustrate precisely this scenario—role within the company rather than type of control and threshold range. If control is exercised in another manner, a description of how the control is exercised must be provided; if it is also based on a determinable ownership interest, the threshold range must also be specified (Art. 14 TJPV).

Information about the chain of control must be obtained and reported only if one of the following conditions is met (Art. 15 TJPV): The chain includes at least two intermediaries, legal entities, or trusts; it includes a trust or a fiduciary relationship; or restrictive measures have been imposed against one of the beneficial owners under the Embargo Act or the Act on Frozen Assets of Politically Exposed Persons.

No Simplified Procedure What is available for limited liability companies (GmbH) and single-member corporations (Ein-Personen-AG) is not available for cooperatives.

The TJPV provides for a simplified reporting procedure for limited liability companies (GmbH) in Art. 35 and for single-member stock corporations in Art. 36. There is nothing comparable for cooperatives. Although Article 19 of the TJPG allows the Federal Council to establish simplified identification and verification rules or a simplified reporting procedure for certain types of legal entities with limited risks, it has not yet made use of this provision for cooperatives.

This is noteworthy because, in the case of cooperatives in particular, the risk profile is low due to the mandatory “one member, one vote” principle. In practice, this means that your cooperative goes through the same procedure as a stock corporation (AG) with a complex shareholder structure—even if, in the end, only a single person is reported.

For comparison: the simplified procedure for a limited liability company (GmbH) and the variant for a single-person corporation (AG).

The Three Obligations of a Cooperative: Identify, Document, Report—and What Applies in the Absence of Cooperation.

Identify and Verify (Art. 7 TJPG) The cooperative obtains personal information as well as details regarding the nature and extent of control. It verifies identity with the due diligence required by the circumstances and requests supporting documentation from members, beneficial owners, or third parties.

Documentation and Retention (Art. 8 TJPG) The information must be documented, kept up to date, and made accessible in Switzerland at all times. If identification or verification is unsuccessful, this must also be documented—along with the steps taken. Information and supporting documents must be retained for ten years after the person in question has ceased to hold that status.

Reporting (Art. 9 TJPG) The following information must be reported: the person’s details, as well as the nature and scope of the audit; in the case of the substitute rule, the position must also be reported. The cooperative must also report information about itself and about the person making the report (Art. 19 TJPV).

If a member fails to cooperate

If the cooperative cannot identify a beneficial owner or verify their identity, it must report, pursuant to Art. 21 TJPV, all relevant information available to it—including which members have failed to comply with their reporting obligation—and additionally designate the highest-ranking member of the governing body as the contact person. This person is expressly not registered as a beneficial owner. This is the key distinction from the subsidiary reporting under Art. 4(2) TJPG, in which the same person appears as the beneficial owner—in the case of a cooperative, both approaches may lead to the same person, but with different entries in the registry.

The special access rule under Art. 8(4) TJPG applies only to public limited companies (AG) and limited liability companies (GmbH). For cooperatives, the general requirement remains that the documented information must be accessible in Switzerland at all times—a requirement you are already familiar with from the cooperative member registry under Art. 837 OR.

Two Ways to File: Electronic Platform or Commercial Registry Office—and What Is Required for Access.

Electronic platform
The standard procedure. The filing is submitted via the federal government’s electronic platform in accordance with the Business Relief Act (Art. 26 TJPV) to the register maintained by the Federal Office of Justice.

Via the Commercial Register Office (Art. 11 TJPG)
This is particularly straightforward for a cooperative when filing under the alternative provision: The person who is then deemed to be the beneficial owner is already registered as an officer in the Commercial Register. If the cooperative has a fact entered in the register, it may submit the report to the cantonal office—provided it confirms that the beneficial owners are registered as members or officers and that there are no others. The information submitted is not public within the meaning of Art. 936 of the Swiss Code of Obligations.

What you need to prepare for access.

The cooperative must authorize at least one person in writing. The form is sent by mail (Art. 27 TJPV).

The power of attorney must be signed in accordance with the registered signing authority—by hand on paper, or electronically with a qualified electronic signature and a timestamp in accordance with ZertES.

Authorized persons must register and authenticate themselves; identity verification is based on a passport, an ID card, or a foreigner’s identity card (Art. 28 and 29 TJPV).

The cooperative requires a UID (Art. 30 TJPV).

The senior member of the governing body is responsible for the registration (Art. 12(1) TJPG). This responsibility may be expressly delegated to other individuals or third parties (Art. 12(2) TJPG)—but the responsibility remains with the senior member. For cooperatives with volunteer management, this is the point that is most likely to be overlooked: The executive committee bears personal liability, even if the administration is handled by an administrative office.

Most initial registrations fail due to issues with power of attorney and authentication. We handle the preparation and guide you through the process.
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What members must report themselves: Rarely regarding share certificates, more often regarding agreements and representation rights.

Anyone who, alone or jointly with third parties, holds shares in an amount that enables ultimate control over the cooperative must report the beneficial owner to the cooperative (Art. 13(1) 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. The report must be submitted within one month of the establishment of control.

Due to the “one share, one vote” principle, this obligation rarely applies to cooperatives—it only becomes relevant when someone reaches the capital threshold through share certificates. Article 14 of the TJPG is of greater practical importance: Anyone who exercises control in another manner or through a chain of control must report directly to the cooperative. It is precisely these cases—a statutory right of representation, an agreement among members—that are relevant in the context of cooperatives.

Consequences of inaction: Fines, suspension—and a personal risk for the executive board.

The obligation arises directly from the law, not only upon request by the authorities.

Sanctions under the TJPG

Legal basis Consequence

Art. 43 TJPG Fines of up to CHF 500,000 for intentional violations of the reporting obligations under Articles 9–11, 13, or 14, or for providing false information to the supervisory authority

Art. 44 TJPG A fine of up to CHF 100,000 for anyone who intentionally fails to comply with a final decision of the supervisory authority

Art. 38(2) TJPG Suspension of the affected members’ rights to participate and property rights in the event of repeated violations

Art. 38, para. 3 TJPG Order for dissolution and liquidation in accordance with bankruptcy laws if the legal entity also clearly no longer engages in business activities or possesses any realizable assets

Art. 33(4) TJPG Ex officio registration if no notification has been filed by the deadline

Art. 45, para. 4 TJPG Statute of limitations for criminal prosecution begins only after seven years

The fine is primarily imposed on one person

Art. 43 TJPG applies to anyone who acts intentionally. In conjunction with Art. 12 TJPG, this refers to the highest-ranking member of the governing body. According to Art. 45(1) TJPG, federal administrative criminal law applies, which—for violations in business operations—allows the legal entity to be held liable instead of the responsible individual only in cases involving minor fines. In the case of a cooperative with a volunteer board of directors, this poses a personal risk to an individual who generally receives little or no compensation for their work. Be sure to record in the minutes who assumes the responsibility and what actions were taken.

Behind the scenes, the registering authority assigns each legal entity to a risk category—high, medium, or low (Art. 64 TJPV). An entry in the registry results in at least a “medium risk” classification. Factors taken into account include, among others, the legal form and country of incorporation, the nationality and residence of the beneficial owners, the nature of control, and the existence of fiduciary relationships and trusts.

The list of cooperative members remains unchanged under Art. 837 of the Swiss Code of Obligations (OR)—and exemptions under the previous law do not apply.

The register under Art. 837 of the Swiss Code of Obligations (OR) must continue to be maintained unchanged. The board of directors shall enter the first and last names or the business name and the address of all members, maintain the register in such a way that it can be accessed at any time in Switzerland, and retain the supporting documents for ten years after a member’s removal from the register.

Until now, cooperatives were not required to identify beneficial owners—the relevant provisions of the Swiss Code of Obligations applied to public limited companies (AG) and limited liability companies (GmbH). The transitional provision of Art. 50 TJPG regarding the retention of the old register therefore also applies only to these two legal forms, and the exemption under Art. 49 TJPG does not apply to you.

That’s the downside: While public limited companies (AG) and limited liability companies (GmbH) can build on preliminary work, your cooperative is starting from scratch. The upside is that the result usually consists of a single person.

Frequently Asked Questions About Cooperatives

Is every cooperative affected?

In principle, yes. Exceptions, as specified in Article 3 of the TJPG, include occupational pension funds, subsidiaries in which more than 75 percent of the shares are held by publicly traded companies, and legal entities in which at least 75 percent of the ownership rights are held by public authorities. Being a nonprofit organization does not, in and of itself, constitute an exemption.

Can anyone even reach the voting threshold in a cooperative?

A single member practically never can. Under Article 885 of the Swiss Code of Obligations (OR), each member has exactly one vote, and this provision is mandatory; since Article 831(1) OR requires at least seven members, a single member’s share of the votes is at most around 14 percent. The situation is different in the case of a joint agreement: in that case, the total share of votes held jointly counts, and in a small cooperative, two to three people are sufficient for this.

Who is reported if no one reaches the threshold?

In that case, the highest-ranking member of the governing body is deemed to be the beneficial owner by default. According to Article 20(3) of the TJPV, this is the chairperson of the executive board if a separate executive body exists; otherwise, it is the president of the board of directors. In addition, the position held within the cooperative must be specified.

Does the two-year deadline apply to our cooperative?

It applies if all beneficial owners are registered in the Commercial Register as members or as officers. If the substitute rule applies and the person in question is registered as an officer, this requirement is met and the report must be submitted by October 1, 2028. If, on the other hand, a member reaches the capital threshold through share certificates but is not listed in the Commercial Register, the shorter deadlines apply.

Is there a simplified reporting procedure for cooperatives?

No. Articles 35 and 36 of the TJPV provide for a simplified procedure only for limited liability companies (GmbH) and single-member stock corporations (Ein-Personen-AG). Although Article 19 of the TJPG allows the Federal Council to establish simplified rules for certain types of legal entities, it has not yet made use of this authority for cooperatives.

Does the registration replace the cooperative member registry?

No. The register under Article 837 of the Swiss Code of Obligations (OR) must continue to be maintained as before, including the retention of supporting documents for ten years after a member’s removal. It serves as the basis for the audit under the TJPG but does not replace it.

We are a housing cooperative with municipal participation. Are we exempt?

Only if at least 75 percent of the membership rights are held directly or indirectly by a local government. A minority stake held by the municipality does not exempt the cooperative. In such cases, it must also be determined whether the local government exercises control in other ways through a statutory right of representation on the board of directors.

Can we outsource the calculation and updating of this information?

Yes. Article 12(2) of the TJPG expressly permits the reporting obligation to be delegated to other persons within the company or to third parties. Responsibility for proper execution remains with the highest-ranking member of the governing body, which is why transparent documentation of the process is crucial.

Has your question been answered? Then complete the review and submission directly in the management tool.
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Legal Basis and Additional 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)

Swiss Code of Obligations: Cooperatives (Art. 828 et seq. CO), Voting Rights (Art. 885 CO), Register of Cooperative Members (Art. 837 CO)

More on this site: Responsibilities of the Board of Directors · Corporation · Limited Liability Company (GmbH) · Association and Foundation · Deadlines · Frequently Asked Questions

Last updated: September 16, 2026.

Bring your cooperative up to date now

Conduct the audit in a structured manner, document the results with supporting rationale, and have deadlines and changes in the chairmanship monitored rather than simply tracking them in a calendar.

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Situation	Must be reported
Separate management body in place	The Chairperson of the Executive Board
No separate management body	The President of the Administration
Liquidation	The liquidator
Staying of Enforcement Proceedings	The Trustee

Situation	Deadline	Reference Date
All beneficial owners are registered in the Commercial Register as shareholders or as members of the governing body	2 years after entry into force	1 October 2028
Other cooperatives subject to mandatory regular audits, classified as “other companies”	4 months after entry into force	February 1, 2027
Other cooperatives that do not meet the requirements for a limited audit	6 months after entry into force	April 1, 2027
First amendment to the commercial register entry after entry into force—if earlier	1 month from this entry	Ongoing
Cooperative to be newly established after October 1, 2026	1 month from entry in the commercial register	Ongoing
Change to a fact entered in the Transparency Register	1 month from the date of becoming aware	Ongoing

Starting situation	Beneficial owner	What to Keep in Mind
Housing cooperative, 80 members, equal shares	The Chair of the Board of Directors, in a subsidiary capacity	Neither the voting threshold nor the capital threshold was met. The review must nevertheless be documented.
Cooperative without share certificates	The Chair of the Board of Directors, in a subsidiary capacity	In the absence of cooperative capital, the capital audit is entirely waived; only the method of verification by other means remains to be clarified.
One member holds 40% of the share capital	This member	The capital threshold has been reached, even though the person has only one vote. The range reported is 25 to 50 percent.
Shares are held by a corporation; one person owns 100% of this corporation	This person, provided that the corporation holds at least 25% of the capital	Indirect control. The public limited company’s stake in your cooperative is reported as the scope of control.
The bylaws grant an umbrella organization the right to appoint a majority of the board of directors	Review of the chain of control behind the umbrella organization	Verification by other means. If the chain does not lead to a natural person, the default rule applies.
The municipality holds a 30% stake and, according to the bylaws, appoints two of the five board members	As a general rule, the chair of the board of directors; alternatively	The exception does not apply below 75 percent. A municipality is not a natural person, and two out of five seats do not constitute a majority.
Cooperative association with three member cooperatives	Review of the chain of control behind each member cooperative	Approximately 33% of the votes each exceed the threshold. Because the members are legal entities, the chain must be traced further.
Several members coordinate their actions through a contract	The parties involved, when a threshold is reached collectively	In the case of a joint agreement, the total jointly held volume counts, not the individual share.

Legal basis	Consequence
Art. 43 TJPG	Fines of up to CHF 500,000 for intentional violations of the reporting obligations under Articles 9–11, 13, or 14, or for providing false information to the supervisory authority
Art. 44 TJPG	A fine of up to CHF 100,000 for anyone who intentionally fails to comply with a final decision of the supervisory authority
Art. 38(2) TJPG	Suspension of the affected members’ rights to participate and property rights in the event of repeated violations
Art. 38, para. 3 TJPG	Order for dissolution and liquidation in accordance with bankruptcy laws if the legal entity also clearly no longer engages in business activities or possesses any realizable assets
Art. 33(4) TJPG	Ex officio registration if no notification has been filed by the deadline
Art. 45, para. 4 TJPG	Statute of limitations for criminal prosecution begins only after seven years