Transparency Registers: Switzerland and Germany
Anyone who owns companies in both countries faces two registries—and should be aware of the differences before drawing conclusions from one to the other. These differences start with the threshold, extend to the issue of public disclosure, and end with a sanction that exists only in Germany.
In a nutshell
- Switzerland
- TJPG, effective October 1, 2026
- Germany
- GwG, since 2017
- Threshold CH
- At least 25%
- Threshold DE
- More than 25%
- Public CH
- No Access
- Public Access (Germany)
- Legitimate interest
- Recognition
- No reciprocity
- Fines published
- Only in Germany
Two systems with different origins
The most striking difference is structural in nature: In Germany, the transparency register is part of the Money Laundering Act. In Switzerland, the legislature has enacted a separate law.
A separate federal law with accompanying regulations, effective as of October 1, 2026. The reporting requirement is separate from anti-money laundering law; the AMLA continues to regulate the due diligence obligations of financial intermediaries in addition to this.
Sections 18 et seq. of the Anti-Money Laundering Act (AMLA) govern the registry within the framework of anti-money laundering law. It has existed since 2017; since the abolition of the presumption of notification on August 1, 2021, it has been a full registry with an active registration requirement.
In practice, this means one thing above all: there is no mutual recognition. Anyone holding companies in both countries must file two separate reports—with different information, different thresholds, and different deadlines.
The Direct Comparison
| Point | Switzerland (TJPG) | Germany (GwG) |
|---|---|---|
| Legal basis | Separate federal law with regulations | Part of the Money Laundering Act, §§ 18 ff. |
| Threshold value | At least 25% of the capital or voting rights (Art. 4 TJPG) | More than 25% (Section 3(2) of the Money Laundering Act) |
| Substitute rule | Highest-ranking member of the governing body (Art. 4(2) TJPG) | Deemed beneficial owner: the legal representative or managing director |
| Reported personal information | Last and first names, date of birth, nationalities, municipality, ZIP code, and country of residence (Art. 10 TJPV) | First and last names, date of birth, place of residence, nationality, and the nature and extent of the economic interest (Section 19 GwG) |
| Extent of control | Three threshold bands instead of a percentage (Art. 13 TJPV) | Type and extent of the economic interest |
| Public Access | None; only the agencies listed in Art. 25–27 TJPG | Members of the public only if they have a legitimate interest and with a limited dataset |
| Deviation reports | Financial intermediaries (Art. 30 TJPG) and government agencies (Art. 31 TJPG) | Reports of discrepancies pursuant to § 23a GwG by obligated parties and authorities |
| Fees | Registration, amendment, deletion, and confirmation are free of charge (Art. 41(1) TJPG) | Annual fee for maintaining the register pursuant to the Transparency Register Fee Regulation |
| Fault | Intent Only (Art. 43 and 44 TJPG) | Recklessness is also sufficient (Section 56 GwG) |
| Penalty Framework | Fines of up to CHF 500,000; up to CHF 100,000 for failure to comply with an order | Up to 100,000 euros; for serious, repeated, or systematic violations, up to 1 million euros or twice the amount of the benefit obtained |
| Publication of sanctions | Not provided for | Publication of final decisions pursuant to § 57 GwG |
The difference that makes all the difference
It looks tiny, but it isn’t. Art. 4 of the TJPG refers to at least 25 percent, while § 3(2) of the GwG refers to more than 25 percent.
A second difference lies in the system. The TJPG recognizes four categories of control that must be examined independently of one another—including “control by other means” under Art. 3 TJPV, which explicitly covers veto rights, appointment rights, and capital instruments. Anyone who conducts the review according to the German model and stops after the first match will submit an incomplete report in Switzerland. Details can be found under “What Data Is Required for the Report.”
Same structure, two results: The tool checks according to Swiss rules and reports the type of control, threshold range, and disclosure requirement separately.
Launch Management ToolThe Issue of Public Disclosure
Here, the two systems have developed differently—and the German development has been more dynamic.
- Originally, Section 23(1), Sentence 1, No. 3 of the Money Laundering Act (GwG) allowed all members of the public to inspect the records.
- The ECJ Ruling In its judgment of November 22, 2022, in Joined Cases C-37/20 and C-601/20, the European Court of Justice declared unrestricted public access to be incompatible with data protection requirements.
- Legitimate Interest Since then, members of the public have been required to justify their request and demonstrate a legitimate interest. Such interest is recognized, among other things, when verifying one’s own registration, as well as in research conducted by journalists and nongovernmental organizations related to the fight against money laundering.
- Reduced Data Set Those granted access do not see everything: last name and first name, month and year of birth, country of residence, all nationalities, and the nature and extent of the economic interest.
Sanctions: Amount vs. Visibility
At first glance, Switzerland appears to have stricter regulations. Upon closer inspection, the picture is mixed.
Up to CHF 500,000 under Art. 43 TJPG—but the basic elements of the offense require intent. Anyone who inadvertently misses a deadline themselves fails to meet it. Nevertheless, negligent failure to supervise can still be covered under Art. 6(2) VStrR if an authorized person acts intentionally. The administrative level intervenes in any case without fault: requests, notes, ex officio entries, and procedural costs.
Up to 100,000 euros; in cases of serious, repeated, or systematic violations, up to 1 million euros or twice the amount of the benefit obtained. Reckless conduct is also covered. To this end, the Federal Administrative Office evaluates, among other things, changes to the commercial register.
Another difference concerns the party against whom the penalty is imposed. In Germany, fines can be imposed on both the company and the executive responsible for the offense. In Switzerland, under administrative criminal law, the penalty is generally directed against the individual responsible for the offense; according to Art. 7 VStrR, the legal entity is only liable for fines of up to 5,000 francs. For more information, see Fines and Sanctions.
We handle the work for the Swiss side
Capture the structure once, review control categories according to the TJPG, and monitor deadlines for each company. For the German side, you will continue to work with your local consultant there.
- Review the structure according to Swiss rules, not based on the German outcome
- Review all four control categories of the TJPG
- Determine the threshold range and control type for each person
- Monitor deadlines for each Swiss company
- Keep documentation accessible from Switzerland
What This Means for Swiss Companies
Five points to consider if you manage both sides.
- Don’t assume theGerman result applies. If you’ve already filed in Germany, you have a good foundation—but not the result. Thresholds, control categories, and disclosure requirements differ.
- Check the 25 percent ownership thresholdExactly 25 percent leads to different results in the two countries. This is the most common reason why a takeover fails.
- Four Categories Instead of a Single ReviewVeto rights, appointment rights, options, and voting restrictions must be reviewed individually in accordance with Articles 3 and 4 of the TJPV.
- Manage Deadlines SeparatelyThe Swiss transition periods under Art. 51 TJPG have nothing to do with the situation in Germany. The first one expires on January 1, 2027.
- Two sets of documentationThe Swiss documentation requirement under Art. 8 TJPG mandates access from Switzerland—if the group’s records are stored in Germany, this must be specifically ensured.
Details about your case
This point applies to groups with companies in both countries.
If you have companies in both countries Five typical structures and what needs to be done in each country.
| Structure | In Switzerland | In Germany |
|---|---|---|
| Swiss AG with a German subsidiary GmbH | The AG files its tax return in accordance with the TJPG, with its own filing deadline under Art. 51 TJPG | The GmbH is independently subject to the reporting requirement; the entry in the commercial register does not replace the report |
| German GmbH with a Swiss subsidiary AG | The subsidiary files a report in accordance with the TJPG; the beneficial owners are determined based on the chain of control | The parent company reports in accordance with the Anti-Money Laundering Act (GwG) |
| German company with a Swiss branch | The German company is itself subject to reporting requirements under Art. 2(1)(b) of the TJPG; the deadline is 6 months pursuant to Art. 53 of the TJPG | Reporting under the Anti-Money Laundering Act (GwG) remains unchanged |
| Swiss company with real property in Germany | Reporting under the TJPG as a Swiss legal entity | Foreign associations may be subject to reporting requirements under § 20 GwG when acquiring real estate; as of January 1, 2026, authorities, certain obligated parties, and notaries must immediately report discrepancies in real estate information pursuant to § 23b GwG |
| German company with real estate in Switzerland | Subject to Art. 2(1)(b)(3) of the TJPG; upon acquisition, the land registry freeze under Art. 40 of the TJPG applies | Reporting under the Anti-Money Laundering Act (GwG) remains unchanged |
The Swiss side in detail: branches of foreign companies, holding companies, and real estate companies.
Frequently asked questions
Does a filing in Germany also apply to Switzerland?
No. The two registries are based on different laws and do not recognize each other’s entries. A German company with a Swiss subsidiary files a report in Germany under the Money Laundering Act, and the subsidiary files a report in Switzerland under the TJPG—two separate reports with different information and deadlines.
What is the threshold?
It varies, and the difference lies in the crucial detail. Article 4 of the TJPG sets the threshold at at least 25 percent, while Section 3(2) of the GwG sets it at more than 25 percent. Someone who holds exactly one-quarter is considered the beneficial owner in Switzerland, but not in Germany according to the wording of the law.
Is the registry public?
Not in Switzerland: Access is limited to the authorities specified in Articles 25 through 27 of the TJPG. In Germany, access was originally intended for all members of the public; following the European Court of Justice ruling of November 22, 2022, a legitimate interest must be demonstrated, and only a limited set of data is displayed.
What applies to our German subsidiary?
It is subject to reporting requirements in Germany. Since the abolition of the presumption of notification on August 1, 2021, the German register has been a full register—a reference to a commercial register entry no longer replaces the notification. The Swiss parent company reports separately in accordance with the TJPG.
What applies to a Swiss subsidiary of a German corporate group?
As a Swiss legal entity, it is subject to reporting requirements under Article 2 of the TJPG, with its own transition period under Article 51 of the TJPG. If the German parent company is not publicly traded, no exception applies; the beneficial owners must be determined through the chain of control.
How do the sanctions differ?
In Switzerland, Article 43 of the TJPG provides for a fine of up to 500,000 Swiss francs; the basic offense requires intent. However, under Article 6(2) of the Administrative Penal Code, negligent failure to exercise supervision may also be penalized if an authorized person acted intentionally. In Germany, violations are administrative offenses under Section 56 of the Money Laundering Act (GwG), which can also be committed through recklessness; fines range up to 100,000 euros and, in the case of serious, repeated, or systematic violations, up to one million euros or twice the economic benefit obtained.
Are fines published?
In Germany, yes: Section 57 of the GwG provides for the publication of final measures and unappealable fine decisions. The TJPG does not contain a corresponding provision. Instead, in Switzerland, the note pursuant to Article 34 of the TJPG is made visible—though only to authorities with access to the registry.
Is there a fee for registration?
In Switzerland, registration, amendments, deletions, access to the register, and confirmation of registration under Article 41(1) of the TJPG are free of charge; however, reminders, requests, orders, and extracts are subject to a fee. In Germany, an annual fee is charged for maintaining the register in accordance with the Transparency Register Fee Regulation.
Has your question been answered? Then check your Swiss companies in the management tool.
Launch Management ToolLegal Basis and Further Resources
- Switzerland: 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)
- Germany: Money Laundering Act (GwG) as well as the information published by the registry authority and the Federal Office of Administration. This overview is provided for informational purposes only and does not replace an examination by a consultant licensed in Germany; German law has undergone several changes in recent years
- More on this site: TJPG and GwG · Branch Office · Holding Company · Fines and Sanctions · Frequently Asked Questions
Last updated: September 16, 2026.
The German report is a basis, not a conclusion
Threshold values, control categories, and reporting requirements differ—and the Swiss deadlines run independently. We review your structure according to Swiss regulations and handle the reporting for the Swiss companies.