TJPG for Fiduciary Firms
Your clients will ask you who will handle this. Before you answer, it’s worth considering three things: what roles you play in this process, what your retainer agreement actually covers—and that the bottleneck isn’t in the reporting itself, but in the hundreds of powers of attorney that arrive by mail.
In a nutshell
- Role 1
- Assigning Authority
- Role 2
- Governing body mandate
- Role 3
- Financial intermediary, if applicable
- Delegation
- Does not protect you
- Bottleneck
- Powers of attorney by mail
- Lever
- Simplified procedure
- Deadlines
- Staggered across the portfolio
- Duty to provide information
- This applies to you, too
Three roles you need to keep straight
You can hold multiple roles simultaneously for the same client. Each role has its own responsibilities and risks.
Art. 12(2) of the TJPG allows the responsible person to delegate the reporting obligation to third parties. They then carry out what the company is required to do—the obligation remains with the company.
If you serve on the board of directors or in management, the responsibility under Art. 12(1) TJPG may apply directly to you—in that case, you are not an agent but the addressee.
Anyone subject to the Anti-Money Laundering Act (GwG) has their own due diligence obligations and, under Art. 30 TJPG, the duty to report any discrepancies identified to the transparency register.
What the delegation means for you
Art. 12(2) of the TJPG transfers the execution, not the responsibility. For you as the agent, this means: The client remains liable—but you are not excluded from liability.
You are liable for what you have undertaken to do. If you fail to file a report that you have promised to file, you are liable to the client for any resulting damages—such as litigation costs, fees, or a fine imposed on her.
Art. 43 and 44 TJPG require intent. The reporting obligation itself applies to the company; you are covered by Art. 6(1) VStrR, which applies the penal provisions to natural persons who have committed the offense in the course of business activities on behalf of another. Art. 43(c) of the TJPG—providing false information to the supervisory authority—applies directly to any person in any case. The penalty is imposed on the person who acted, not your company; only in the case of a fine of no more than 5,000 Swiss francs and disproportionate investigative costs may the legal entity be prosecuted instead, pursuant to Art. 7 of the VStrR.
Third parties who have a contractual relationship with the audited legal entity, its shareholders, partners, or beneficial owners must provide the audit authority with information or supporting documents to the extent that these are necessary for the audit. Article 321 of the Swiss Criminal Code (StGB) remains reserved.
Providing this evidence makes the sale easier: Your client can see, for each company, what has been reported and which deadlines are pending—without having to ask you.
Launch multi-client viewFirst, review the engagement agreement
Almost every existing contract predates the law. A contract for bookkeeping, financial statements, and tax returns does not automatically cover the identification of beneficial owners—and this identification is the most time-consuming part.
- Clarify the scope of servicesAre you responsible for the identification, the reporting, or both? The reporting alone can be completed in minutes, but the identification cannot be done in a structure with a shareholder agreement.
- Regulate cooperationWho will collect the information from the parties involved? The reporting obligations of the owners under Art. 13 TJPG are directed at the company, not at you—without the company’s cooperation, you cannot fulfill these obligations.
- Setting DeadlinesWhen does your internal deadline begin? The one-month period under Art. 10 TJPG begins when the company becomes aware of the matter—agree that the client will inform you immediately.
- Limiting LiabilityYou cannot vouch for information provided by the client or her parties involved. Make it clear that you are relying on the accuracy of that information.
- Determining CompensationInvestigation, initial reporting, and ongoing updates are three distinct services involving varying levels of effort.
Plan the portfolio in four phases
The deadlines are staggered based on legal form and audit status. With over a hundred clients, this means you don’t have just one deadline, but five—and the first one is three months after the law takes effect.
| Wave | Mandates | Key date |
|---|---|---|
| First | Review and exclude exceptions under Art. 3 TJPG | above all else |
| Wave 1 | Corporation subject to mandatory regular audit | January 1, 2027 |
| Wave 2 | GmbH and other companies subject to statutory audits | February 1, 2027 |
| Wave 3 | Corporation without requirements for a regular audit | March 1, 2027 |
| Wave 4 | Other Companies | April 1, 2027 |
| Later | Mandates in which all beneficial owners are entered in the commercial register as shareholders or as a governing body | October 1, 2028 |
The Key: The Simplified Procedure
For a typical SME portfolio, the bulk of the reporting work is eliminated for a significant portion of the mandates.
Applicable if all shareholders are natural persons, all beneficial owners are also shareholders, control is exercised exclusively through capital, and the company is neither in liquidation nor in bankruptcy nor under a stay of debt repayment. A confirmation is filed.
More specifically: only one shareholder, who is registered in the Commercial Register as the sole member of the board of directors and is the sole beneficial owner. Here, too, a confirmation is sufficient.
The Bottleneck: Access and Powers of Attorney
The filing itself takes only a few minutes. Accessing the system, however, does not—and this requirement applies to each company.
- Power of Attorney by Mail Pursuant to Art. 27 TJPV, the legal entity is sent a power of attorney form. It must be signed and returned. With a hundred clients, that means a hundred pieces of mail sent out and a hundred returns.
- Registration and Authentication The authorized representative must register and authenticate themselves in accordance with Articles 28 and 29 of the TJPV before they can act.
- UID: According to Article 30 of the TJPV, the company requires a UID. For existing mandates, it is already available; for newly established companies, it is only available after entry in the commercial register.
- Report Only Then—Everything Prior Is a Prerequisite. Anyone who waits until the deadline is running to begin this process has already shortened it.
What is a single task for one company becomes a process for a hundred
That’s exactly what the multi-client view is designed for: portfolio, waves, status, and response rates—all in one place.
- Record inventory with legal form, audit status, and structure
- Assign each client to its wave and procedure
- Track the status of each client at a glance
- Obtain information from parties involved with a response confirmation
- Provide documentation that the client can review herself
Details about your case
This point applies to trust companies that are also subject to anti-money laundering laws.
If you are also subject to the Anti-Money Laundering Act (AMLA), the obligation to report discrepancies does not stop at your own client accounts.
Many trust companies are members of a self-regulatory organization. This adds an obligation that can become problematic within the client relationship.
Art. 30 of the Anti-Money Laundering Act (TJPG) requires financial intermediaries to report any discrepancies they identify between the information in the transparency register and the information they hold to the register. This obligation stems from your role as a financial intermediary—not from whether the client is one of your own.
It should also be noted that the parallel revision of the Anti-Money Laundering Act applies to advisors. According to the explanations provided by the Federal Department of Finance, this also includes the provision of addresses or premises as a domicile or registered office for legal entities. Anyone offering domiciliation services should separately verify their own regulatory status—this is a matter of the Anti-Money Laundering Act (AMLA), not the Tax Administration Act (TJPG). The areas where the two regimes diverge are outlined under the TJPG and the Anti-Money Laundering Act.
Frequently Asked Questions
As a trust company, are we ourselves subject to reporting requirements?
For your own company, yes, provided it is organized as an AG or GmbH—just like any other legal entity. For client accounts, however, you do not file as a trustee but as an authorized representative for the respective company. The reporting obligation remains with the company; the responsibility for filing lies with you.
Are we liable if a report is not filed?
Contractually, in any case, within the scope of the assignment undertaken. Under criminal law, Articles 43 and 44 of the TJPG are limited to intentional acts—but anyone acting as an authorized representative who intentionally fails to report falls under these provisions. And because Article 45(1) of the TJPG declares administrative criminal law applicable, the penalty under Article 6 of the VStrR is imposed on the natural persons involved, not on the company.
Does our existing engagement agreement cover the TJPG?
Probably not, because it predates the law. An agreement covering accounting, financial statements, and taxes does not automatically include the identification of beneficial owners. Make it explicitly clear whether you are obligated to identify, report, or both—and who is responsible for obtaining the information from the relevant parties.
How do we plan for a portfolio of one hundred clients?
In four phases. First, eliminate the exceptions under Article 3 of the TJPG; then bundle the client accounts subject to the simplified procedure under Articles 35 and 36 of the TJPV; next, address the companies subject to the shortest deadline under Article 51(3) of the TJPG; and finally, tackle the complex structures. The two-year rule under Article 51(2) of the TJPG applies only to mandates in which all beneficial owners are listed in the commercial register as partners or officers.
What are the benefits of the simplified procedure?
The reporting requirement is reduced to a confirmation; no further information on the beneficial owner is required. For a typical SME portfolio consisting of single-member GmbHs and single-member AGs, this affects a significant portion of the mandates. However, the identification and documentation requirements under Articles 7 and 8 of the TJPG remain in effect in all cases.
How do we gain access to the platform for our clients?
Per company. Under Article 27 of the TJPV, the legal entity receives a power-of-attorney form by mail; the authorized representative registers and authenticates themselves in accordance with Articles 28 and 29 of the TJPV; and the company needs a UID under Article 30 of the TJPV. With a hundred clients, that means a hundred pieces of mail—that is the logistical bottleneck, not the reporting itself.
Do we have to provide information to the supervisory authority?
Yes. Under Article 37(2) of the TJPG, third parties who have a contractual relationship with the audited legal entity, its shareholders, partners, or beneficial owners must provide information or supporting documents to the extent that they are necessary for the audit. Professional secrecy under Article 321 of the Swiss Criminal Code (StGB) remains reserved.
What applies if we are also a financial intermediary?
In that case, you are also subject to the obligation under Article 30 of the TJPG to report any discrepancies found between the registry information and the information in your possession to the transparency registry. This obligation stems from your role as a financial intermediary and applies even to your own clients.
Has your question been answered? Then we’ll set up multi-client management for your portfolio.
Launch multi-client viewLegal 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) and Ordinance of June 12, 2026 (TJPV, SR 955.31)
- Federal Act on Administrative Criminal Law (VStrR) and the Federal Department of Finance’s explanatory notes on the TJPV
- More on this site: Responsibilities of the Board of Directors · Incorporation · Deadlines · TJPG and GwG
Last updated: September 16, 2026.
The bottleneck is the response, not the notification
If you start with a hundred powers of attorney in the fall, you won’t be finished by January. We’ll set up multi-client management with you, assign the portfolio to the waves, and run the power-of-attorney processes in batches.