Evidence and documents
The TJPG requires that the identity of beneficial owners be verified with due diligence and that the basis for this verification be documented. It does not specify what documents these are. This page explains what the only explicitly mentioned document is, which documents support the verification in practice, and how long you must keep them available.
In a nutshell
- List of Supporting Documents in the Law
- Does not exist
- Standard
- Due Diligence
- Specifically named
- Only a copy of the ID
- Documentation
- Even if unsuccessful
- Retention
- 10 years
- Start of the deadline
- Loss of the status
- Access
- At any time from Switzerland
- Trustees
- 5 years from the end of the engagement
The law does not set out a list of documents
Anyone expecting a list will search in vain. Art. 7(2) TJPG is phrased broadly: The company must verify the identity of the beneficial owners and their status as such with the due diligence required by the circumstances, and to this end, it must request the relevant supporting documents from shareholders, partners, beneficial owners, or other third parties.
Two terms define this provision, and both are relative. “As required by the circumstances” means: risk-dependent. A single-member limited liability company (GmbH) with a local shareholder requires less than a structure spanning three jurisdictions involving a fiduciary relationship. “Relevant” means: suitable for answering the specific question—not as much as possible.
The only document mentioned for the review
For the verification of beneficial ownership, the ordinance specifically names a single document. Art. 10(2) TJPV: The legal entity must determine whether the person has an AHV number. If the person does not have one, the legal entity must obtain a copy of a Swiss or foreign passport, a Swiss or foreign identity card, or a Swiss foreigner’s identity card.
No copy of identification is required. The authority maintaining the register identifies the person using the AHV number and cross-checks the information against the central database (Art. 59(2) TJPV).
A copy of identification is required. The authority may request an AHV number from the central clearing house; once the information has been verified and the number assigned, the copy used for this purpose must be destroyed (Art. 59(3) TJPV).
For a complete list of the information that must be reported, see “What Data Is Required for the Report.”
Documents Supporting the Review
The following list is not derived from the law itself, but from the questions it raises. Different supporting documents are required for each audit question.
| Review question | Typical Documents |
|---|---|
| Who directly holds shares? | Share register, membership register, list of cooperative members, subscription certificates, share purchase agreements |
| How many votes are associated with them? | Articles of Incorporation—in particular provisions regarding voting shares or the voting power of common shares—and regulations governing participation certificates |
| Who is behind a subsidiary? | Extract from the commercial register, organizational chart of the group, share register of the intermediate company; for foreign entities, an equivalent extract from the relevant register |
| Have the participating parties coordinated their actions? | Shareholder Agreement, Partnership Agreement, Pooling Agreement, Voting Agreement |
| Does anyone exercise control in any other way? | Articles of Incorporation and Certificate of Incorporation, Agreements with Shareholders, Option Agreements, Convertible Bonds, Participating Loans, Agreements Regarding Appointment or Veto Rights |
| Are shares held in trust? | Trust agreement, nominee agreement, confirmation of the principal |
| Is there a trust in the chain? | Trust deed, information on applicable law, documents regarding the trustee, protector, and beneficiaries, indication of whether the trust is discretionary |
| Is the person’s identity correct? | Verification of whether an AHV number is available; if not, a copy of identification pursuant to Art. 10(2) TJPV. The review pursuant to Art. 7(2) TJPG goes beyond this and is based on the supporting documents relevant to the specific issue under review. |
| Did the parties involved cooperate? | Notifications from owners pursuant to Art. 13 TJPG, correspondence, and inquiries with dates and responses |
Determining which document answers which question is the real work. The tool uses your structure to identify the relevant verification questions—and requests only the supporting documents needed to answer them.
Launch Management ToolDocument, even if you don’t succeed
Art. 8 TJPG distinguishes between two cases, and the second one is regularly overlooked.
The information specified in Art. 7, paras. 1 and 3 of the TJPG must be documented. The company ensures that it is up to date and that it can be accessed in Switzerland at any time.
If the company has been unable to identify the beneficial owner or to verify the beneficial owner’s identity or status in a satisfactory manner, the company shall document this fact and the steps taken.
The second scenario is not a failure but an outcome provided for by law. It results in a report pursuant to Art. 21 TJPV: The company shall provide all available relevant information, including details regarding any chain of control and which shareholders or partners have failed to fulfill their obligations under Art. 13 TJPG, and shall additionally designate the highest-ranking member of the governing body as the contact person.
Retention and Access
| Who | What | How long |
|---|---|---|
| Legal entity | Information and Supporting Documents Regarding Beneficial Owners | 10 years after the person has ceased to hold that status (Art. 8(3) TJPG) |
| Trustee | Information pursuant to Art. 16, paras. 2–4 TJPG | 5 years after the end of the term of office (Art. 16, para. 7 TJPG) |
| Stock corporations and LLCs | The register of beneficial owners drawn up under the previous law | 10 years after entry into force; the previous law applies to supporting documents (Art. 50 TJPG) |
| Foreign legal entity with administration in Switzerland | List of owners | To be maintained at the place of actual administration (Art. 18 TJPG) |
Access from Switzerland, not storage in Switzerland
Art. 8(1) of the TJPG requires that the information be accessible in Switzerland at all times. The law does not specify a required storage location. Storage at a foreign parent company or with a service provider is therefore not precluded—as long as access from Switzerland is possible at all times and does not depend on the goodwill of another entity.
For AGs and GmbHs, Art. 8(4) of the TJPG applies in addition: The person who is authorized to represent the company under Art. 718(4) or Art. 814(3) of the OR and who is domiciled in Switzerland must have access to the documented information. Anyone who outsources administrative functions must ensure this access through organizational measures—a password known only abroad is not sufficient.
The documentation survives any change in management
The initial filing is a one-time event. The documentation remains in effect for ten years beyond the termination of the ownership interest—and must survive any changes to the board of directors, the fiduciary mandate, and the filing system.
- Assign supporting documents to the audit questions they answer
- Record inquiries to parties involved and their responses
- Ensure permanent access from Switzerland
- Maintain a change log with dates
- Organize retention for more than ten years
Checklist for Your Filing System
Six components that make up a dossier.
- One dossier per companystructure, proof of ownership, articles of incorporation, and contracts all in one place, not scattered across accounting, the secretariat, and legal correspondence.
- One sheet per beneficial ownerpersonal information, AHV verification, copy of ID if necessary, type of verification, threshold range, and the supporting documentation.
- The inspection reportWhich of the four control categories were inspected, with what results, and based on what—even in cases where the result was negative.
- CorrespondenceRequests sent to parties involved, including dates, reminders, and responses. If there is no response, this is your only evidence.
- Change LogWhen changes were made, what was changed, and why. Without a history, it will be impossible to prove years later that an earlier report was correct at the time.
- Access controlsWho has access in Switzerland, particularly the person referred to in Art. 718(4) or Art. 814(3) of the Swiss Code of Obligations (OR)—and how access is transferred when that person leaves the organization.
Details about your case
These points concern the participation of the parties involved and oversight.
Who Owes You Documentation: Three Obligations—and Why the Request Itself Constitutes Documentation.
You do not have to obtain the documents yourself; rather, you must request them. The law imposes three obligations on the parties involved for this purpose.
Upon request by the company, they must provide the information or supporting documents necessary to verify the identity of the reported person or their status as a beneficial owner. For information already reported under the previous law, a one-month deadline applies pursuant to Art. 49(2) TJPG.
They must cooperate in the verification process by providing the company, the shareholders, or the partners with the necessary information and supporting documents.
Third parties who have a contractual relationship with the legal entity, its shareholders, partners, or beneficial owners must provide the audit committee with information or supporting documents to the extent that these are necessary for the audit. Article 321 of the Swiss Criminal Code (StGB) regarding professional secrecy remains reserved.
Because the company’s deadline runs regardless of cooperation, these obligations should be included in the shareholders’ agreement or in regulations—with a deadline that is shorter than your own.
The wording leaves open whether refusal is a criminal offense. Art. 43(a) TJPG imposes a fine for a violation of “the reporting obligation under Articles 13, 14, or 17.” The obligation to provide evidence is set forth in Art. 13(4) TJPG, but it is not a notification in the strict sense. Whether it is covered by the criminal provision is therefore unclear—yet another argument for securing the obligation contractually rather than relying on criminal law.
When the supervisory authority asks: Who is obligated to provide information—and what constitutes a criminal offense.
The audit office at the Federal Department of Finance conducts audits to verify the accuracy, completeness, and timeliness of the information—either on a risk-based basis or by random sampling. It may have certain audit activities performed by third parties.
Pursuant to Art. 37(1) TJPG, the legal entity, shareholders, partners, and persons in equivalent positions, third parties in the control chain, and beneficial owners must provide the necessary information and supporting documents to the supervisory authority.
The supervisory authority may also take the measures provided for in Art. 38 TJPG: request additional information, order the amendment or deletion of information, have the audit result noted, and—in the event of repeated violations—suspend the participation and property rights of the affected shareholders or partners.
Whether Supporting Documents Are Submitted with the Report Information is reported, not documents—with one exception.
Art. 9(5) of the TJPG expressly authorizes the Federal Council to require that the company submit supporting documents. The ordinance does not contain a general obligation to submit documents—according to Art. 20 of the TJPV, it is the information that must be reported, not the documents. However, Article 59(3) of the TJPV requires that a copy of the identification document be available to the authority, as the authority uses it to apply for the AHV number. The platform will show how this process works.
This is to be distinguished from documents required by the procedure itself: Anyone who files a report through the Commercial Register Office and authorizes a third party to do so must attach the power of attorney to the report in accordance with Art. 34(2) TJPV. If there are reasonable doubts as to the authenticity of a handwritten signature, the supervisory authority may require certification during an inspection (Art. 34(5) TJPV).
Frequently asked questions
What specific supporting documents does the law require?
The law does not provide a list. Article 7(2) of the TJPG refers to the relevant supporting documents that the company requires from shareholders, partners, beneficial owners, or third parties, and sets the standard of due diligence required under the circumstances. The only document expressly mentioned for this verification is the copy of an identification document pursuant to Article 10(2) of the TJPV, and even then only if no AHV number is available. This is to be distinguished from procedural documents such as the power of attorney, which, pursuant to Article 34(2) of the TJPV, must be attached to the notification submitted to the Commercial Register Office.
Do we have to submit supporting documents with the filing?
Article 9(5) of the TJPG authorizes the Federal Council to provide for this. The ordinance does not require the general submission of supporting documents; according to Article 20 of the TJPV, it is the information that must be reported, not the documents. However, Article 59(3) of the TJPV requires that the registry authority have a copy of an identification document on file when it uses it to apply for an AHV number.
How long do we have to keep the documents?
Ten years pursuant to Article 8(3) of the TJPG. For trustees, Article 16(7) of the TJPG provides for a five-year period following the termination of their term of office. The list of beneficial owners prepared under previous law must be retained by AGs and GmbHs for ten years after the TJPG takes effect, pursuant to Article 50 of the TJPG.
When does the ten-year period begin?
Not from the date the document was created, but from the date on which the person in question ceased to be a beneficial owner. Anyone who holds a stake for twenty years must therefore keep the documents available for thirty years.
Are we allowed to store the documents abroad?
Article 8(1) of the TJPG requires that the information be accessible in Switzerland at all times. The storage location itself is not specified. What matters is that access from Switzerland is guaranteed at all times—even if a foreign parent company or service provider operates the systems.
What happens if a shareholder fails to provide supporting documents?
In that case, pursuant to Article 8(2) of the TJPG, you must document that identification or verification was unsuccessful and record the steps taken. In the report, pursuant to Article 21 of the TJPV, you must provide all available relevant information, including which shareholders have failed to fulfill their obligation, as well as the highest-ranking member of the governing body as the contact person.
Who is authorized to request our documents?
The supervisory authority and third parties commissioned by it. Pursuant to Article 37 of the TJPG, the obligation to provide information applies to the legal entity, shareholders and partners, third parties in the chain of control, and beneficial owners. Professional secrecy under Article 321 of the StGB remains reserved.
Is an extract from the commercial register sufficient as proof?
For some information, yes; for the crucial information, no. The extract lists the governing bodies and, in the case of a GmbH, also the shareholders and their capital shares. It provides no information about who is behind a subsidiary, whether a voting rights agreement exists, or whether shares are held in trust. Other documents are required to answer these questions.
Is your question answered? Then set up the documentation in the management tool.
Launch Management ToolLegal Basis and Additional Sources
- 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)
- More on this site: Register of Beneficial Owners · Fines and Sanctions · Report Changes · What Data to Report · Responsibilities of the Board of Directors · Case Studies · Frequently Asked Questions
Last updated: September 16, 2026.
You won’t realize which document is missing until you’re asked for it
Those who document the audit as they conduct it have the evidence. Those who have to reconstruct it later do not. We set up the filing system so that it lasts ten years beyond the end of the investment.