1. Overview: the relationship between the TJPG and the TJPV
The Transparency Act (TJPG) requires Swiss legal entities to identify and verify their beneficial owners and report them to a central, non-public Transparency Register. The TJPV is the corresponding implementing ordinance: it provides concrete rules for the terms and procedures left open by the Act. The detailed TJPG check explains whether and how your company is specifically required to report.
The ordinance is divided into nine chapters: obligations of domestic legal entities, obligations of foreign legal entities, obligations of holders of interests, the reporting procedure, register content and extracts, access and reporting of discrepancies, review and control, fees, and final provisions. For more detailed information, see the FDF Explanations on the TJPV and the Consultation Results Report.
The Transparency Register is maintained by the Federal Office of Justice (FDJP); a control office within the Federal Department of Finance (FDF) monitors the accuracy, completeness and currency of the data.
2. Who is considered a beneficial owner?
The core of the ordinance consists of the concepts of control. A beneficial owner is always a natural person who ultimately controls a legal entity.
Direct and indirect participation Art. 1–2
A participation is direct if capital or voting rights are held without any intermediate persons. It confers control from at least 25%.
A participation is indirect if it is held through intermediate entities. Control exists if someone holds more than 50% of the intermediate entities.
Control by other means Art. 3
Even without a sufficient participation, a person may exercise control – for example through the right to appoint or remove governing bodies, veto rights over material decisions or the ability to obtain profit distributions.
Trusts Art. 5–6
Ultimate control over a trust includes persons who can dispose of or invest trust assets, determine distributions, change beneficiaries, appoint trustees or dissolve the trust.
3. What information must be obtained?
- About a natural person Art. 10
- Last name and first name, date of birth, nationalities, as well as municipality, postal code and country of residence.
- About a legal entity Art. 11
- Company name or name, legal form, registered office, as well as the UID or an equivalent foreign number.
- Type of control Art. 12
- Whether control is exercised alone or in coordination with others, directly or indirectly, and through a participation or by other means.
- Extent of participation Art. 13–14
- Range: 25–50%, more than 50–75%, or more than 75%.
4. What is reported to the Transparency Register?
About itself, the legal entity reports its identification details and the name and function of the person making the report.
For each beneficial owner, the identification details as well as the type and extent of control must be reported.
5. Foreign legal entities
The rules apply accordingly to foreign legal entities. In addition, they report the connecting factor as well as a representative or an address for service in Switzerland.
6. Obligations of holders of interests
Holders of interests must provide the reporting legal entity with the information on the type and extent of control.
7. The reporting procedure
Electronically via the platform of the Confederation Art. 26–31
As a general rule, reporting is carried out via the electronic platform of the Confederation under the Business Relief Act.
Via the commercial register office Art. 32–34
Alternatively, the report can be submitted via the commercial register office.
Simplified procedure Art. 35–38
Simplifications are available for straightforward cases (e.g. a GmbH with only natural persons as shareholders or a single-shareholder AG).
8. Register content, confirmations and extracts
Upon request, a confirmation of registration, a full extract (without the OASI number) and a reduced partial extract are available.
9. Access to the register and reporting of discrepancies
Only authorised authorities as well as financial intermediaries and advisors have access within the scope of their due diligence obligations.
Every query is logged and retained for two years.
10. Review, control and risk categories
The authority maintaining the register verifies the information against the Commercial Register and identifies persons using the OASI number. Legal entities are assigned to risk categories (low, medium, high).
11. Fees
Registration, amendment and deletion are free of charge. Fees apply for extracts (cost-recovery principle). Reminders and rulings are subject to fees.
12. Entry into force and pilot register
The TJPV entered into force at the same time as the TJPG on 1 October 2026. A pilot operation was planned in advance.
13. Annex: further enactments
The annex to the TJPV amends provisions in several other ordinances, including the Commercial Register Ordinance and the Ordinance on the Business Identification Number.