Reporting changes
The initial filing is a one-time event, while ongoing updates are an ongoing task. However, this task is more limited in scope than many assume: Changes in ownership must be reported only when a threshold is exceeded; four categories of changes are entirely exempt; and the authority updates some of the information itself. The key is to identify the remaining cases—and to do so in a timely manner.
In a nutshell
- Deadline
- 1 month from the date of notification
- Basis
- Art. 10 TJPG
- Holding
- Only when crossing a threshold
- Company, Headquarters, ZIP Code
- Authority to which the case is transferred
- Civil status name
- No notification required
- Group effect
- Change applies everywhere
- Removal of a Person
- Deletion in the register
- Route
- Platform or HR Office
The basic rule: one month from the date of notification
Article 10 of the TJPG consists of a single sentence: The company must report any change to a fact entered in the Transparency Register to the Transparency Register within one month of becoming aware of it.
Two elements of this provision deserve attention. First, the obligation is tied to a fact that has been recorded—if something was never entered in the registry, it cannot be subject to the reporting requirement even if it changes. Second, the deadline begins to run from the time the change is known, not from the time the change occurs.
Most missed deadlines stem from an unreported share transfer. Record the reporting obligations of the parties involved and see who reported what and when.
Launch Management ToolWhat Triggers a Report
Any change to the information in the registry must be reported. In practice, this includes the following cases:
| Reason | What Changes |
|---|---|
| Share transfers above or below a threshold | A person’s threshold range; removal or addition of a person, if applicable |
| New Shareholder Agreement or Pool Agreement | Acting in concert; under certain circumstances, individuals may become beneficial owners who would not be so on their own |
| New veto, appointment, or option rights | Control by other means pursuant to Art. 3 TJPV |
| Loss of a beneficial owner | Deletion of Information About This Person |
| Changes in the Presidium or Executive Board in the case of a report under the substitute provision | The reported person and their position |
| Change of residence of a registered person to another municipality | Municipality, ZIP code, and country of residence |
| Restructuring of the Participation Chain | The chain of custody, if it is part of the entry pursuant to Art. 15 TJPV |
| Liquidation or debt restructuring | In the event of a filing under the substitute provision, the liquidator or trustee takes the place of the previous highest-ranking member (Art. 20(3) TJPV) |
| Loss of the prerequisites for the simplified procedure | The next filing will proceed according to the regular rules |
What Does Not Trigger a Report
This is where the real relief lies. The ordinance excludes two areas.
Changes in ownership without exceeding a threshold
According to Art. 39(3) TJPV, a change in a shareholding must be reported only if it results in a threshold under Art. 13(1) TJPV being exceeded or fallen below. The three bands are decisive.
| Change | Subject to reporting? |
|---|---|
| 30% to 40% | No—remains in the 25 to 50 percent range |
| 45% to 60% | Yes – exceeds the 50 percent threshold |
| 80% to 90% | No – remains within the range above 75 percent |
| 26% to 20% | Yes – falls below the entry threshold; the person is excluded |
| 76% to 70% | Yes – moves from the top band to the middle band |
Four groups are eliminated entirely
Art. 39, para. 4 of the TJPV completely exempts certain changes from the reporting requirement:
Changes made in the Commercial Register to the company name or legal name, legal form, registered office, and ZIP code of the domicile address.
Name changes resulting from a declaration in accordance with the provisions of the Civil Code, its Final Title, and the Partnership Act, as listed therein. This covers not only civil status matters related to marriage and divorce, but also name changes pursuant to Art. 30(1) of the Civil Code.
Name changes under foreign law and changes relating to foreign nationalities that are reported to Swiss authorities for entry into ZEMIS, Ordipro, or E-VERA.
Changes relating to Swiss citizenship.
What the authority tracks itself
Art. 40 TJPV describes what happens behind the scenes—and includes a simplification that primarily benefits groups.
- Transfers from the Commercial Register The authority maintaining the register transfers changes to the company name, legal form, registered office, or ZIP code (Art. 40, para. 3, letter a, TJPV).
- Transfer from the Central Database of Persons It transfers changes to last name, first name, or citizenship resulting from a comparison with the Central Clearing House (Art. 40(3)(b) TJPV).
- Correction of Obvious Errors It may correct obvious errors in a report, provided that this can be verified using data from the Commercial Register or the Central Database of Persons (Art. 40(2) TJPV).
- Notification and Confirmation It notifies all affected legal entities of the change made and confirms the entry (Art. 40(4) TJPV).
How to Report a Change
The standard procedure under Art. 39(1) TJPV. According to paragraph 2, the platform retrieves the existing entry to assist with data entry—so you modify the existing record instead of entering everything anew.
Possible under the conditions set forth in Art. 11 TJPG, i.e., if the beneficial owners are registered in the Commercial Register as shareholders or as members of a governing body and there are no others. The procedures set forth in Arts. 32 through 34 TJPV apply.
According to Art. 12 TJPG, the highest-ranking member of the executive body remains responsible. The task may be delegated, but responsibility for its proper execution may not—see “Responsibility of the Board of Directors” for more details.
Updates rarely fail due to a lack of willingness
It fails because no one realizes that an event triggers a deadline.
- Monitor threshold bands instead of reporting every movement
- Identify triggers where the threshold rule does not help
- Periodically ask stakeholders about changes
- Keep track of monthly deadlines starting from the date of notification
- Keep a record of changes with dates and reasons
Details about your case
The sections above cover the typical cases. These points concern deletions, the cooperation of the parties involved, and incorrect entries.
When Something Is Omitted: Three Cases for Deletion—and the Start of Your Retention Period.
Not every change is a correction—some lead to deletion. Art. 24 TJPG distinguishes between three cases.
| Case | Consequence |
|---|---|
| A legal entity under Swiss private law is deleted from the Commercial Register | The entry in the Transparency Register is deleted |
| A legal entity governed by foreign law is no longer subject to the Act | Deletion upon request |
| A natural person ceases to be the beneficial owner or is no longer part of the chain of control | The information about this person is deleted |
In the registry itself, deleted data is retained for ten years pursuant to Art. 46(2) TJPG before being destroyed.
What the parties involved must report: Two one-month deadlines preceding yours.
This information is not provided automatically. The law imposes two parallel obligations on the parties involved, both with a one-month deadline.
They must report any change to the information reported under paragraph 1 to the company within one month after becoming aware of it.
Any person who has acquired the status of beneficial owner must report any change to the information specified in Art. 13, para. 1 TJPG within one month.
An annual confirmation closes the gap: By having the parties involved confirm once a year that nothing has changed, you gain both knowledge and proof at the same time.
If the entry is incorrect: discrepancies, notes—and how to correct them yourself.
An outdated or incorrect entry does not go unnoticed. Under Art. 30 TJPG, financial intermediaries must report discrepancies between the information in the registry and the information they hold to the Transparency Registry. Authorities do the same under Art. 31 TJPG if they have doubts about the accuracy, completeness, or timeliness of the information. According to the wording of Article 30 of the TJPG, the obligation to report discrepancies applies to financial intermediaries; although advisors have access to the registry under Article 27 of the TJPG, they are not mentioned in Article 30 of the TJPG.
The result is a note in the entry pursuant to Article 34 of the TJPG. This note indicates that doubts exist and, pursuant to Article 64(2) of the TJPV, leads at least to classification in the “medium risk” category. The authority maintaining the register requests the legal entity to correct or supplement the information and sets a reasonable deadline for doing so.
Failure to Report: Fines, Notices, Risk Categories—and What Matters Most in Practice.
| Basis | Consequence |
|---|---|
| Art. 43 TJPG | Fines of up to CHF 500,000 for intentional violation of the reporting obligation under Articles 9–11—Article 10 is included |
| Art. 34 TJPG | Note in the entry following a discrepancy report or if a request remains unanswered |
| Art. 64 para. 2 TJPV | A note results in at least a “medium risk” category |
| Art. 38 TJPG | Measures taken by the supervisory authority up to the suspension of participation and property rights |
| Art. 45, para. 4 TJPG | Statute of limitations for criminal prosecution only after seven years |
The note is more relevant in practice than the fine. It is visible to any agency with access to the registry—and thus to the banks you work with.
Frequently asked questions
When does the one-month period begin?
From the time of knowledge, not from the time the change occurs. Section 10 of the TJPG requires notification within one month after the company has become aware of the change. This pushes the deadline back, but in return requires that you take organizational steps to ensure you are made aware of the change.
Do we have to report every transfer of shares?
No. According to Article 39(3) of the TJPV, a change in shareholding must be reported only if it causes a threshold under Article 13(1) of the TJPV to be exceeded or fallen below. A shift from 30 to 40 percent remains within the same range and does not trigger any reporting requirement, whereas an increase from 45 to 60 percent does.
Which changes do we not have to report at all?
Article 39(4) of the TJPV lists four categories: changes made in the commercial register to the company name or individual name, legal form, registered office, and ZIP code of the domicile address; name changes resulting from a declaration in accordance with the provisions of the Swiss Civil Code (ZGB), its Final Title, and the Partnership Act, as specifically listed in Article 39(4)(b) of the TJPV; name changes under foreign law and changes in foreign citizenship reported to the Swiss authorities for ZEMIS, Ordipro, or E-VERA; and changes in Swiss citizenship.
What does the authority track on its own?
Pursuant to Article 40(3) of the TJPV, the authority maintaining the register transfers changes to the company name or legal name, legal form, registered office, or ZIP code from the Commercial Register, and changes to the surname, first name, or citizenship from the central database of persons. It then notifies all affected legal entities and confirms the entry.
What applies in the event of a change in the presidency?
If the highest-ranking member of the governing body was reported in accordance with the substitution rule, a change in this person constitutes a change to a registered fact and must be reported within one month. The exemption under Article 39(3) of the TJPV does not apply here because it concerns only changes in ownership.
What happens when a beneficial owner ceases to exist?
Under Article 24(3) of the TJPG, information about a natural person is deleted from the transparency register as soon as that person ceases to be a beneficial owner or is no longer part of the chain of control. At that moment, the ten-year retention period under Article 8(3) of the TJPG begins for you.
Can we have an incorrect entry corrected?
Yes. Article 32 of the TJPG entitles all legal entities to report discrepancies concerning them to the transparency register and to submit a request for correction. Procedurally, the same rules apply mutatis mutandis as for change notifications, in accordance with Article 58 of the TJPV.
What are the consequences if we fail to report a change?
Article 43 of the TJPG provides that intentional violation of the reporting obligation under Articles 9 through 11 is punishable by a fine of up to 500,000 Swiss francs; Article 10 is included in this provision. In addition, an outdated entry may result in a financial intermediary reporting a discrepancy, which in turn may lead to a notation that results in at least a “medium risk” category.
Has your question been answered? Then have the update monitored 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: Fines and Sanctions · What Data to Report · Evidence and Documents · Deadlines · Frequently Asked Questions
Last updated: September 16, 2026.
Updates never end
Shareholdings shift, leadership changes, and people move. We monitor the threshold ranges, identify the triggers where the threshold rule does not apply, and send reminders one month before the deadline expires.