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Deadlines and Cut-off Dates

Transparency Register Deadline: By when must you file?

The TJPG does not specify a single deadline, but rather four different deadline regimes: phased transition periods for existing companies, one month for newly formed companies, one month following each change to the commercial register, and one month for each subsequent change in beneficial ownership. Which deadline applies to you depends on your legal form, audit requirements, registered office, and your Commercial Register entry. This page lists all deadlines along with their legal basis.

What deadline applies to your company?

Just five questions at most, and then you’ll know your deadline and the legal basis for it. No registration required, no data storage.

Question 1

Was your company already in existence on October 1, 2026?

The decisive factor is whether the company was entered in the commercial register before that date.

The calculator provides a non-binding guide based on standard legal cases and does not replace a review of the specific case. The text of the law is always authoritative.

Transitional periods for existing companies

Companies that were already registered in the Commercial Register as of October 1, 2026, do not have to file immediately. The TJPG schedules the initial filing based on legal form and audit status. The larger and more thoroughly audited the company, the shorter the deadline—the legislature assumes that the ownership data for such companies is already accurate.

Transitional periods for the first report of beneficial owners under the TJPG
Your Situation Deadline Key date Legal basis
A stock corporation that is required to have its books audited 3 months December 31, 2026 Art. 51, para. 3 TJPG
Other companies subject to mandatory audits 4 months January 31, 2027 Art. 51, para. 3 TJPG
Stock corporation without a regular audit 5 months February 28, 2027 Art. 51, para. 3 TJPG
Other companies and legal entities 6 months March 31, 2027 Art. 51, para. 3 TJPG
Foreign legal entities with ties to Switzerland 6 months March 31, 2027 Art. 53 TJPG
All beneficial owners are already registered in the Commercial Register as shareholders or as members of a governing body 2 years September 30, 2028 Art. 51, para. 2 TJPG

The fourth line provides an abridged version of the text. The law refers there to “other companies that do not meet the requirements for a limited audit, and other legal entities.” In practice, limited liability companies (GmbH) and cooperatives without a regular audit fall under this six-month deadline. The staggered deadlines under paragraph 3 apply only to “other legal entities”—that is, those not already covered by the two-year deadline in paragraph 2.

What does “statutory audit” mean?

Companies that exceed two of the three thresholds in two consecutive fiscal years—total assets, revenue, and annual average full-time equivalents—are subject to a regular audit. Public companies and companies required to prepare consolidated financial statements are also subject to a regular audit. If you are unsure which type of audit applies to your company, check the extract from the Commercial Register: The auditor is listed there, or an “opt-out” is noted.

Deadline Calendar 2026–2028

The deadlines in chronological order. They apply only as long as no changes to the commercial register occur in the meantime.

  1. October 1, 2026: The TJPG, TJPV, and the revised GwG take effect. The Transparency Register begins operations. All transition periods begin.
  2. December 31, 2026: First filing due for stock corporations subject to mandatory auditing.
  3. January 31, 2027: First filing due for other companies subject to mandatory audits.
  4. February 28, 2027: First filing due for stock corporations not subject to a statutory audit.
  5. March 31, 2027: First filing due for all other companies, other legal entities, and foreign legal entities with a connection to Switzerland.
  6. September 30, 2028 Final deadline: Initial reporting due for companies in which all beneficial owners are already registered in the Commercial Register as shareholders or members of a governing body—provided that no changes have been made to the Commercial Register since October 1, 2026.

You know the deadline. File your report now.

The management tool guides you from the ownership structure to the submitted report—and keeps track of any subsequent changes.

  • Enter ownership structure
  • Identify beneficial owners
  • Submit the notification and file the confirmation
  • Automatic alert for every commercial register change
  • Thresholds, deadlines and documentation in one place

Details about your case

The table above covers the standard case. These factors may extend or modify your deadline.

The One-Month Rule for Commercial Register Changes Any change in the Commercial Register shortens your deadline to one month.

The law phrases it the opposite way from what one would expect. According to Art. 51(1) TJPG, the notification must be made within one month after the first change to the Commercial Register entry following the law’s entry into force—“but no later than” the deadlines specified in paragraphs 2 and 3. The one-month deadline is therefore the rule; the staggered deadlines and the two-year period are merely the absolute limits. As soon as you make a change, the one-month rule applies.

What Counts as a Change in the Commercial Register

  • Relocation of the registered office or new business address
  • New or Departing Officer
  • Change in Signing Authority
  • Capital Increase or Reduction
  • Amendment to the Articles of Incorporation
  • Change of company name
  • Change of Purpose
  • Admission or Withdrawal of Shareholders (GmbH)
  • Change or Opt-out of the Auditing Firm

The law is based on the change to the Commercial Register entry, not on the underlying resolution. Weeks may elapse between the resolution, the filing, the registration, and publication in the SHAB; therefore, the start of the one-month period must be determined on a case-by-case basis. To be on the safe side, calculate the period starting from the earliest of these dates.

Case A

A GmbH with two shareholders listed in the commercial register would have until September 30, 2028. In March 2027, a new managing director takes office.

The report is due one month after the registration, i.e., in December 2026.

Case C

A corporation is planning to revise its articles of incorporation in the spring of 2027 anyway and wants to coordinate the initial filing with that process.

Recommended: File the report before the change takes effect; then only the standard amendment period applies.

Monitor deadlines: Receive an automatic notification for every change to the commercial register.

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Newly Formed Companies: Report newly registered companies within one month.

Legal entities established after October 1, 2026, have no transition period. The report is due within one month of the company’s entry in the Commercial Register (Art. 9(4) TJPG). For legal entities governed by foreign law, the one-month deadline begins when they become subject to the law—for example, through the registration of a branch office, the transfer of actual management to Switzerland, or the acquisition of real property.

Simplified Registration Process for GmbHs and Single-Shareholder AGs When GmbHs and single-shareholder AGs can register more easily—and what it costs.

Some companies can file their initial registration using the simplified procedure; the relevant information is taken directly from the commercial register. However, the requirements are strict, and they apply only to the initial registration: Monitoring deadlines, reporting changes, and maintaining documentation remain your responsibility in all cases. First, check whether you qualify at all.

LLC

All shareholders are natural persons, all beneficial owners are also shareholders of the GmbH, and control is exercised through ownership of capital. No liquidation, bankruptcy, or debt moratorium. Shareholders with at least a 25 percent equity stake are then confirmed (Art. 35 TJPV). If a person holds a higher percentage of voting rights than equity shares, the simplified procedure does not apply—the thresholds cannot then be automatically calculated from the commercial register.

Simplified procedure applicable.

Single-shareholder stock corporation

There is only one shareholder, who is a natural person, registered in the Commercial Register as the sole member of the board of directors and, at the same time, the sole beneficial owner. The company is also not in liquidation, bankruptcy, or debt restructuring. The sole shareholder is then confirmed as the beneficial owner (Art. 36 TJPV).

Simplified procedure applicable.

All others

As soon as a legal entity is involved, there are multiple shareholders, an intermediate company is involved, or control is exercised in any other way, the requirements are not met. There is no partial application.

Reporting under the standard procedure.

The simplified procedure does not change the deadlines. It merely reduces the effort involved in the initial filing. If not all requirements are met, it cannot be applied—there is no partial application; in that case, a complete filing with a structural analysis is required. The management tool checks both for you: whether you qualify and what else needs to be done.

Access and Filing via the Tool The management tool handles the setup for you.

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Ongoing Change Notifications Which changes must be reported after the initial notification.

The initial registration is not the end of the process. The information in the Transparency Register must be kept up to date: Every change must be reported within one month, calculated from the date on which the company becomes aware of it (Art. 10 TJPG).

What Triggers a Change Report

  • Sale of shares that exceeds or falls below a threshold
  • Inheritance or gift with a threshold effect
  • Restructuring in the chain of control
  • Control arising or ceasing in other ways
  • Loss of beneficial ownership
  • Change in the municipality or country of residence of a registered person
  • Change in the highest governing body in the case of a subsidiary registration

Update the tool with changes: thresholds, deadlines, and documentation all in one place.

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Deadlines within the company Which deadlines apply between the company, shareholders, and beneficial owners.

Before the company can report to the registry, it must have the information. The TJPG therefore also regulates the flow of reporting within the company—and sets its own deadlines for it. The process flows from the shareholder through the company to the transparency registry.

Shareholders, Art. 13 TJPG

Any person who, alone or jointly with third parties, holds a stake that enables control must notify the company within one month of who the beneficial owner is and provide evidence of this information upon request. Changes must be reported within one month of becoming known. The notification is sent to the company, not to the registry.

Beneficial Owners and Third Parties, Art. 14 TJPG

Any person who acquires the status of beneficial owner must report this to the shareholder or partner holding the relevant shares or interests. If control is exercised in another manner or through multiple companies or persons—that is, through a chain of control—the report must be submitted directly to the company. Any changes must be reported within one month. Beneficial owners and third parties involved in the chain of control must cooperate with the review and provide the necessary information and supporting documents.

Company, Art. 9 and 10 TJPG

The company must review the information received with due diligence and report it to the transparency register. The senior-most member of the governing body is responsible; this task may be delegated to other individuals within the company or to third parties, but responsibility for proper execution remains (Art. 12 TJPG). The details of the reporting person—last name, first name, role in or relationship to the company, and email address—must be provided to the registry in all cases.

If the beneficial owner cannot be identified

If a company is unable to identify its beneficial owners or cannot satisfactorily verify their status, it must report this fact—along with all available relevant information, including details on the chain of control and on those shareholders who have failed to fulfill their disclosure obligations. In addition, the highest-ranking member of the governing body must be designated as the contact person (Art. 9(3) TJPG, Art. 21 TJPV). This contact person is expressly not considered a beneficial owner—they serve solely as a point of contact for the authorities. This must be distinguished from the subsidiary report under Art. 4(2) TJPG, in which the highest-ranking member of the governing body is in fact considered the beneficial owner because no one else meets the criteria. Remaining silent is not an option in this situation: Reporting that no beneficial owner has been identified is itself a mandatory obligation subject to a deadline.

Transitional Exemption for Previous Reports

Shareholders and partners who have fulfilled their reporting obligations under previous law (Art. 697j and 790a OR) and for whom the same person is also the beneficial owner under the TJPG are deemed exempt. However, the company may request missing information—such as date of birth or nationality—which must be provided within one month. The exemption applies to the notification to the company, not to the company’s notification to the registry.

Who Has No Deadline at All: Which Legal Entities Are Exempt from Reporting.

For some legal entities, the question of deadlines does not arise because they are not subject to the TJPG or are expressly exempt.

Not covered

Sole proprietorships, general partnerships, general and limited partnerships, associations, and foundations are not subject to the TJPG.

No reporting requirement, no deadline.

Exceptions

Publicly traded companies and their subsidiaries in which they hold more than 75 percent of the shares, either directly or indirectly, pension funds, and companies in which at least 75 percent of the shares are held by the public.

Exception under Art. 3 TJPG.

Unchanged

The share register under Art. 686 OR and the unit register under Art. 790 OR remain unaffected by the amendment.

To continue to be maintained by the company itself.

Exceptions must be interpreted narrowly and reviewed on a case-by-case basis. Anyone claiming an exception should document the rationale.

What to Do If You Miss a Deadline? Fines, ex officio registration, and the sensible way forward.

A missed deadline cannot be remedied by simply waiting. Anyone who intentionally violates reporting or disclosure obligations or provides false information risks a fine of up to CHF 500,000 (Art. 43 TJPG). Anyone who intentionally fails to comply with a final decision by the supervisory authority—which was issued with a warning of the penalty—may be fined up to CHF 100,000 (Art. 44 TJPG). These are maximum amounts, not flat rates.

Only intentional violations are punishable; mere negligence does not constitute a criminal offense. However, this is not a free pass: Anyone who is aware of their reporting obligation and nevertheless allows the deadline to pass may quickly find themselves in the realm of conditional intent. And the corporate law consequences outlined below do not require intent.

The Federal Department of Finance is the prosecuting and adjudicating authority; the statute of limitations for criminal prosecution is seven years (Art. 45 TJPG). The supervisory authority is the unit within the Federal Department of Finance responsible for audits (Art. 39 TJPG), and the register itself is maintained by the Federal Office of Justice.

In addition to fines, supervisory measures may be imposed (Art. 38 TJPG): If reporting obligations are repeatedly violated or if a violation is not remedied despite repeated requests, the supervisory authority may suspend the participation and property rights of the shareholder or partner in question. Dissolution and liquidation are only imposed if the circumstances warrant it—namely, if the legal entity clearly no longer engages in any business activities and has no realizable assets.

And even before it comes to that: If a legal entity fails to file a report by the deadline set by the registry authority, the authority may enter it ex officio (Art. 33 TJPG). The entry is then made without any action on your part—using the information available to the authority.

In addition, there are fees: While the entry itself is free of charge, reminders, demands, and orders are not. They are calculated based on the time required; the hourly rate ranges from 100 to 150 francs, depending on the expertise required, and surcharges of up to 50 percent may apply in cases of exceptional scope or urgency (Art. 41 TJPG, Art. 68 TJPV). Anyone who lets the deadline pass may therefore end up paying even before a potential fine is imposed.

Missed the deadline? File a late report now. Identify the structure, determine the entitled parties, and submit the report.

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Checklist leading up to your deadline

What you should have ready by the deadline—in the order that requires the least amount of work. Steps 2 through 6 are the most time-consuming; that’s what our software is for.

  1. Check the commercial register extractThe legal form, audit status, and registered individuals determine which deadline applies.
  2. Map out the entire ownership structureList all shareholders with their share of capital and voting rights; for multi-tiered structures, trace the entire chain back to the individual.
  3. Examine control through other meansReview shareholder agreements, veto rights, usufructs, financing arrangements, and permanent representation relationships.
  4. Obtain personal dataThe following information must be obtained: last name and first name, date of birth, nationality, address, and country of residence (Art. 7 TJPG). Of these, the last name, date of birth, nationality, municipality of residence, and country of residence must be reported—not the full address (Art. 9 TJPG).
  5. Determining the nature and scope of controlNot just who, but how: directly, indirectly, through an agreement, or by other means. Regarding scope, a range is sufficient—25 to 50 percent, over 50 to 75 percent, or over 75 percent—an exact percentage is not required. The equity interest is reported; only if the voting rights result in a higher level does that level apply.
  6. Collect and Secure Supporting DocumentsCopies of identification documents, contracts, and share register extracts—to be retained for ten years.
  7. Set up access to the reporting processNo report can be filed without established access. Sending a power of attorney to the registered office address takes weeks—start early or have the management tool handle it.
  8. Define Responsibilities Within the CompanyWho will monitor changes in the future and report them within one month?
  9. Plan Ahead for Upcoming Commercial Register ChangesAny change made after October 1, 2026, will shorten your deadline to one month.
  10. Submit the notification and file the confirmationUsing the management tool, which includes documentation for your records. The confirmation of registration is free; an actual extract from the register must be ordered separately and is subject to a fee.

Frequently Asked Questions About Deadlines

Does my GmbH have to file immediately on October 1, 2026?
No. Transition periods apply to companies that already existed on that date. Depending on the audit status, the deadline falls between January 31, 2027, and March 31, 2027; if all beneficial owners are already listed in the commercial register, the deadline is extended to September 30, 2028. However, any change to the commercial register after October 1, 2026, shortens the deadline to one month.
When does the one-month deadline begin in the event of a change to the commercial register?
It begins on the date of the change to the Commercial Register entry, not on the date of the underlying resolution. The decisive factor is the entry or its publication in the SHAB. In case of doubt, the calculation of the deadline in individual cases should be verified.
Does the two-year deadline also apply to a public limited company (AG)?
Only in exceptional cases. The prerequisite is that all beneficial owners are registered in the Commercial Register as shareholders or as members of a governing body. Shareholders of an AG do not appear in the Commercial Register, which is why this requirement is usually met only if all beneficial owners are also registered as members of a governing body.
What deadline applies to a company incorporated after October 1, 2026?
One month from the date of entry in the commercial register. There is no transition period for newly established companies.
What is the deadline for foreign companies?
For foreign legal entities that already had a connection to Switzerland as of October 1, 2026, a uniform deadline of six months applies, i.e., until March 31, 2027. If the connection to Switzerland is established later—for example, through the registration of a branch office or the acquisition of real property—the one-month deadline begins to run.
Can I use the simplified reporting procedure?
The simplified procedure is available to a limited liability company (GmbH) if all shareholders are natural persons and the persons subject to reporting are precisely these shareholders holding at least 25 percent of the capital. For a single-member AG, it applies if the sole shareholder is a natural person, is registered in the Commercial Register as the sole member of the board of directors, and is also the sole beneficial owner. In both cases, the company must not be in liquidation, bankruptcy, or under a stay of debt enforcement. The information is then taken directly from the Commercial Register. This does not affect the deadlines.
How much does it cost to file a report with the Transparency Register?
Registration in the Transparency Register is free of charge, as are amendments to and deletions of existing entries. Fees apply to reminders, requests, and orders issued by the registering authority or the supervisory body, as well as to the issuance of register extracts. Confirmations of registration are free of charge.
By when must I report a change?
Within one month, calculated from the date on which the company becomes aware of the change. Not only sales of shares must be reported, but also changes in voting rights, control relationships, and personal data, as well as the termination of beneficial ownership.
Within what timeframe must shareholders report to the company?
Within one month of the acquisition of control; changes must be reported within one month of becoming known. This report is submitted to the company, not to the transparency register. The company verifies the information and, in turn, reports it to the register.
What applies if the beneficial owner cannot be identified?
In that case, this circumstance must be reported within the applicable deadline—along with all available relevant information regarding the chain of control and the shareholders who have failed to comply with their disclosure obligations. In addition, the highest-ranking member of the governing body must be reported as the contact person.
What happens if I miss the deadline?
Anyone who intentionally violates the reporting or disclosure obligations risks a fine of up to CHF 500,000 (Art. 43 TJPG); anyone who intentionally fails to comply with a final decision by the supervisory authority risks a fine of up to CHF 100,000 (Art. 44 TJPG). The Federal Department of Finance is the prosecuting and adjudicating authority. Only intentional acts are punishable; mere negligence is not. Irrespective of this, the authority maintaining the register may, ex officio, enter a defaulting legal entity after the deadline has expired, and the supervisory authority may suspend the participation and property rights of the shareholder in question in the event of repeated violations. It is advisable to submit the report without delay and to document the process.
Can I have the deadline extended?
The transition periods are set forth directly in Articles 51 and 53 of the TJPG; the transitional provisions do not provide for a procedure to extend the deadline upon request. Anyone who anticipates difficulties in obtaining the information should document this and consider filing a notice of non-determination rather than allowing the deadline to pass.

Has your question been answered? Then submit the report 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) – Fedlex
  • Ordinance of June 12, 2026, on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPV, SR 955.31) – Fedlex
  • Federal Collection of Examples on the Identification and Reporting of Beneficial Owners – PDF, as of August 13, 2026
  • More on this site: Starting a New Business · Reporting Changes · Corporation · Limited Liability Company · Frequently Asked Questions

Deadline Set—What Now?

The time-consuming part isn’t the reporting itself, but rather identifying the beneficial owners and the ongoing monitoring that follows. Our software handles both—mapping the structure, identifying beneficial owners, and keeping track of deadlines.