Chronik
Key facts about the legislation’s development, insofar as they are relevant to its application.
| Date | Event |
|---|---|
| 26 September 2025 | The Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) is enacted. |
| 12 June 2026 | The Federal Council adopts the corresponding ordinance (TJPV). It specifies the definitions, the information to be reported, access to the registry, and registry management. This was preceded by a consultation process, the results of which were summarized by the Federal Department of Finance in a report. |
| 1 October 2026 | The TJPG and TJPV enter into force. The transparency register, administered by the Federal Office of Justice, begins accepting reports. |
Calendar of Deadlines
All deadlines resulting from the transitional provisions. Which one applies to you depends on your legal form, audit status, and who is ultimately reported.
| Date | Who It Affects | Legal Basis |
|---|---|---|
| 1 January 2027 | Corporations Subject to Mandatory Audits | Art. 51(3) TJPG, 3 months |
| February 1, 2027 | Other companies subject to mandatory regular audits, namely the GmbH | Art. 51(3) TJPG, 4 months |
| March 1, 2027 | Corporations that do not meet the requirements for a regular audit | Art. 51(3) TJPG, 5 months |
| April 1, 2027 | Other companies that do not meet the requirements for a limited audit, as well as other legal entities. Note: According to the wording, a limited-audit GmbH falls under neither this category nor the February 1 provision—see “Open Issues.” | Art. 51(3) TJPG, 6 months |
| April 1, 2027 | Legal entities governed by foreign law that are subject to the Act | Art. 53 TJPG, 6 months |
| 1 October 2028 | Companies in which all beneficial owners are registered in the Commercial Register as shareholders or as members of a governing body | Art. 51(2) TJPG, 2 years |
| October 1, 2036 | End of the retention period for the inventory prepared under previous law for AGs and GmbHs | Art. 50 TJPG, 10 years |
| ongoing | Newly formed companies: 1 month from the date of entry in the commercial register. First amendment to an existing entry after the law takes effect: 1 month from the date of such entry. Amendment to a registered fact: 1 month from the date of knowledge. | Art. 9(4), Art. 51(1), and Art. 10 TJPG |
You can determine which deadline applies to you in just a few minutes: The detailed TJPG Check assigns your company to the correct case group and explains the basis for that assignment. An overview of all regimes is available under “Deadlines.”
Implementation Status
Three points regarding the launch that you should know before planning.
According to Art. 26(1) TJPV, the legal entity must use the electronic platform established under the Business Relief Act for the reporting procedure; the explanatory notes specify the EasyGov platform operated by SECO. In addition, under the conditions set forth in Art. 11 TJPG, the option of filing through the Commercial Registry Office is available.
Article 26(2) of the TJPV allows the FDJP to provide an additional interface through which reports can be transmitted directly from its own systems. During the consultation process, this was requested primarily by service providers who assist legal entities in fulfilling their reporting obligations. According to the explanatory notes, it will not yet be available upon entry into force due to resource constraints.
The power-of-attorney form is sent by mail in accordance with Art. 27 TJPV; the authorized representative must register and authenticate in accordance with Arts. 28 and 29 TJPV; and the company needs a UID in accordance with Art. 30 TJPV. For many companies, the return of these forms determines the timeline, not the report itself.
There is one exception: Anyone who meets the requirements of the simplified registration procedure and is being newly entered into the Commercial Register may submit the registration via the Commercial Register Office in accordance with Art. 37(1) TJPV—without platform access. For more details, see “New Company Formation and Registration Requirements.”
Prior to the system going live, a pilot test will be conducted in accordance with Art. 67 TJPV: The newly established IT infrastructure and interfaces will be tested using real data, with the participation of legal entities, the registry-maintaining authority, the commercial registry offices, the supervisory authority, and the authorized authorities. The pilot test will continue until the law enters into force.
Offene Punkte
While reviewing the law and ordinance, we encountered several passages whose meaning cannot be determined with certainty from the wording alone. We list them here so that you know where an interpretation lies—and we will update this entry as soon as a standard practice emerges.
The provision distinguishes between two categories for companies other than stock corporations: four months if an ordinary audit is required, and six months if the requirements for a limited audit are not met. A limited-audit GmbH falls into neither category; the same applies in the case of an opt-out. Until this is clarified, the shorter deadline is the safer option. More on the GmbH page.
A limited partnership for collective investment schemes (KmGK) is a limited partnership and therefore not a legal entity. However, the provision refers to legal entities under Swiss private law. The wording does not make it clear whether the transition periods apply to it. More on the page about SICAVs, SICAFs, and KmGKs.
The provision requires signatures from persons who, according to their signing authority as recorded in the Commercial Register, are authorized to sign. At the time of incorporation, these persons are not yet registered—they are only registered upon filing the application. It remains to be seen how the authorities will handle this. More under “New Incorporation” and “Reporting Obligation.”
The only legal definition is found in Art. 20(3) TJPV, where it serves to identify the person subject to subsidiary reporting requirements. The wording is general in nature; there is no explicit provision regarding Art. 12 TJPG. Those assigning internal responsibilities should therefore explicitly define them. More under “Responsibilities of the Board of Directors.”
Sources
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), both effective as of October 1, 2026, as well as the Federal Department of Finance’s explanatory notes on the TJPV and its report on the results of the consultation process. The questions listed under “Open Issues” are based on our interpretation of the text and do not constitute legal advice.