Transparency register: a new compliance challenge for Swiss companies

With the adoption of the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LTPM) on 26 September 2025, Switzerland is taking a further step towards enhancing the transparency of legal structures and strengthening its framework for combating money laundering and terrorist financing. The Act will come into force on 1 October 2026, together with it’s implementing ordinance. 

This reform provides for the establishment of a federal transparency register designed to identify the beneficial owners of legal entities. If your company is affected, it is essential to begin  preparing now for the identification and reporting procedures. 

Reporting obligation and access  

This reform will affect the majority of unlisted legal entities acting as legal persons,  in particular, public limited companies (SA), private limited companies (Sàrl), cooperatives, open-ended investment companies (SICAV) or closed-ended investment companies (SICAF), limited partnerships with share capital and collective investment schemes. Certain foreign companies with a branch in Switzerland or whose effective management is located in Switzerland, as well as companies that own property in Switzerland, will also be required to maintain this register. However, foundations and associations, occupational pension schemes, partnerships and certain categories of legal entities, as well as listed companies, will be exempt.¹ 

Companies subject to this obligation will be required to (i) identify their beneficial owners and collect their details, (ii) submit these to the transparency register and (iii) update them in the event of any changes. 

Entries may be made primarily via the EasyGov.swiss platform. The register will become  operational on 1 October 2026. After this  date, the deadline for submitting the required information will vary depending on the type of company and certain other criteria (Articles 51 to 53 of the LTPM). 

Access to the transparency register will not be public.  It will be restricted to certain authorities specifically defined by law. Financial intermediaries and certain professionals subject to the Anti-Money Laundering Act (AMLA) will also be able to access it to enable them to fulfil their due diligence obligations.  

Penalties for non-compliance 

Failure to comply with the reporting anf update obligations may give rise to both administrative and criminal sanctions.   The most severe include  the suspension of the shareholder’s social and property rights in cases of repeated breaches and fines of up to CHF 500,000 in cases of intentional breaches. 

Our recommendations 

The implementation of this register should enable Switzerland to enhance its reputation and safeguard the integrity of its financial and economic centre in an international context where transparency requirements are becoming increasingly stringent. 

To avoid a rush when these new obligations come into force and if your company is one of those affected, we recommend that you start preparing for the implementation of this reform now by identifying and gathering information on your company’s beneficial owners.  

Our team is on hand to support you at every stage of this process, in particular to: 

• Determining whether your company is affected by the new registration obligations and identifying the entities within your group that are subject to reporting 
• Identifying and documenting your beneficial owners in accordance with the legal criteria, including within more complex structures 
• Preparing and submitting registrations to the register within the prescribed time limits 
• Establishing internal processes to ensure that information is kept up to date and to guarantee your ongoing compliance. 

Authors: Virginie von Planta, Simana Muggler and Leanne Suter