Swiss transparency register: company obligations from October 2026

What is the Swiss transparency register?

The Swiss transparency register, also called TranspaReg, is a federal database of companies’ beneficial owners. It enables authorised bodies to identify the individuals behind a legal structure, including where one company owns another.

The aim is to help combat money laundering, terrorist financing and arrangements that conceal control of a business. Parliament adopted the legislation on 26 September 2025. The Federal Council set its commencement date at 1 October 2026, together with the implementing ordinance, referred to here by its French abbreviation OTPM.

How does it differ from the commercial register?

The commercial register publishes information such as a company’s registered name, registered office and authorised representatives. The transparency register identifies the individuals who exercise ultimate control. A board member, a shareholder recorded internally and a beneficial owner are therefore not necessarily the same person.

For an LLC owned directly by its founders, the information may largely overlap. For a corporation owned through a holding company, the analysis must go further. An existing commercial register extract or a bank’s customer identification file does not replace the new filing.

Which businesses must register?

For business owners, the most common cases are Swiss corporations and LLCs. There is no general minimum revenue or employee threshold that exempts a small company.

Exemptions include listed companies and subsidiaries held more than 75% by listed companies, certain supervised pension institutions and legal entities held at least 75% by public authorities. These two percentage tests are different.

A small Geneva LLC is therefore generally affected even if it has no employees. By contrast, a sole proprietor does not have to register merely because their business appears in the commercial register.

How do you identify the beneficial owners?

A beneficial owner is always an individual. Identify who ultimately controls the company, directly or indirectly, alone or acting in concert with others.

The 25% threshold is not the only test

A person directly holding at least 25% of capital or voting rights falls within the test. Exactly 25% is enough. Someone else may also qualify through decisive powers, such as the right to appoint most board members or particular strategic veto rights.

Example: an LLC with three members
Camille holds 50%, Julien 30% and Nora 20%, with proportionate voting rights and no special arrangements. Camille and Julien must be identified as beneficial owners. Nora does not qualify solely through her 20% interest. However, the company must still check for other control rights or arrangements to act in concert.

A holding company requires an analysis of the control chain

Do not simply report the corporate shareholder’s name. Trace ownership to individuals and apply the OTPM’s indirect control rules. For a chain of equity holdings, the ordinance combines, in particular, more than 50% in intermediary entities with a qualifying holding of at least 25% in the company concerned.

For example, Léa owns 80% of Holding SA, which owns 60% of Atelier SA. Without other arrangements, Léa indirectly controls Atelier SA. The legal analysis is not merely a multiplication of percentages: voting rights, agreements and other means of control must also be considered. See our guide to Swiss holding companies for the wider context.

What if nobody meets the criteria?

If no individual meets the statutory tests, the highest-ranking member of the governing body is reported on a subsidiary basis. This differs from a case where a beneficial owner exists but cannot be identified or verified. In that situation, the company must disclose the difficulty, document its enquiries and provide the information available. It should not silently substitute a director for an unknown owner.

What is the deadline for the first filing?

Distinguish existing companies from companies formed after the legislation takes effect. For existing Swiss companies, Article 51 LTPM provides transitional periods starting on 1 October 2026.

A commercial register amendment may bring the deadline forward

The first amendment of a commercial register entry after commencement triggers a one-month deadline for the initial filing, without extending the applicable final transitional deadline. A change of registered office, appointment of a director or another amendment can therefore make the filing due much earlier.

Example in Geneva
An LLC qualifies for the two-year transitional period. A new managing director is then entered in the commercial register on 10 November 2026. The company must arrange its initial filing within one month of that entry. It cannot simply wait until the end of the two years.

The two-year period does not automatically apply to every LLC. Check that each beneficial owner is already registered in the required capacity. If the company does not clearly fit a category, particularly an LLC subject to a limited audit that cannot use the two-year period, obtain confirmation of its deadline based on the statutory wording and official guidance.

New companies and foreign legal entities

A Swiss company formed after commencement must file within one month of its commercial register registration. Foreign legal entities already within scope at commencement have a six-month transitional period under Article 53. Newly arising cases follow the legislation’s reporting rules.

If you are planning a corporate change, coordinate this deadline with the commercial register amendment process.

How do you prepare and file through EasyGov?

For an SME, organised preparation avoids searching for records while completing the form. The following practical sequence can be adapted to your structure.

1. Check scope and timing. Record the legal form, any exemption and commercial register changes planned over the coming months.
2. Map the ownership structure. Start with the company to be reported, list its owners and trace each level. Review agreements and any special voting rights.
3. Identify and verify the relevant individuals. Gather information and evidence explaining each person’s identity and control.
4. Prepare EasyGov access. The user registers with a personal AGOV account and links access to the company and its UID number. Validation can take a few days.
5. Arrange the filer’s permissions. If your accountant will file, grant the relevant rights. Access to another company does not suffice: each entity requires its own connection.
6. Submit the filing and retain confirmation. The service opens when the register begins operating. Check the individuals, control details and filer’s contact information, then retain the registration confirmation.
7. Organise ongoing updates. Decide who must be informed when shares are transferred, an investor joins or control changes.

You can prepare EasyGov access in advance. Creating an account does not itself report the company’s beneficial owners. The official portal is EasyGov.swiss.

What information should you gather?

• Each relevant individual’s surname, first name, date of birth and nationalities.
• Residence information; the filing includes the municipality, postcode and country.
• The nature of control: direct or indirect, through ownership or other means, alone or acting in concert.
• The extent of ownership under the prescribed bands: 25% to 50% inclusive, more than 50% up to 75% inclusive, or more than 75%.
• Additional control-chain information where required, particularly with multiple intermediary levels, a trust or a fiduciary/nominee arrangement.

The ordinance also requires the company to establish whether the person has a Swiss social insurance number (AVS/AHV). If not, a copy of an accepted identity document is required. The internal file must support the information reported; it is more than a copy of the submitted form.

Can you file through the cantonal commercial register?

The legislation allows this where all beneficial owners are recorded there as members or corporate officeholders and the filing accompanies a commercial register transaction. As of 27 September 2026, TranspaReg says this channel is still being prepared. Do not assume an application sent to the Geneva commercial register already transmits the transparency filing automatically. EasyGov is the main route to prepare.

Which LLCs and corporations can use simplified reporting?

The OTPM provides simplified reporting for certain straightforward structures. This reduces the information to enter but does not remove the filing duty.

For an LLC

All members must be individuals. Its beneficial owners must be the members qualifying through a capital holding of at least 25%, under Article 35 OTPM. The company must not be in liquidation, bankruptcy or a debt restructuring moratorium.

An LLC with a holding company as a member therefore does not meet this condition. A third party’s special control rights must not be overlooked simply to use the simplified procedure.

For a corporation with one shareholder

The sole shareholder must be an individual, appear in the commercial register as the sole board member and be the company’s only beneficial owner. The corporation must not be in liquidation, bankruptcy or a debt restructuring moratorium.

Having just one owner is therefore insufficient. A corporation with one shareholder and several board members must examine the ordinary filing procedure.

Who is responsible, and what happens after registration?

Under Article 12 LTPM, the highest-ranking member of the governing body is responsible for the filings. The task may be delegated to an employee or an accounting firm, but responsibility for its proper execution remains. Owners and beneficial owners must also supply the necessary information under their statutory duties.

Keep the information current

As a rule, a change to a registered fact must be reported within one month after the company becomes aware of it. Some information is updated automatically from official records. For example, the OTPM exempts certain company-name and registered-office changes already entered in the commercial register from a separate notification.

A change in the size of an ownership interest requires an update to that extent only when it crosses one of the ordinance’s reporting bands. However, the emergence or departure of a beneficial owner, or a new form of control, must be reviewed promptly.

Retain supporting evidence

Information must remain current and accessible in Switzerland. Records and supporting documents relating to a beneficial owner must be retained for ten years after that person ceases to hold that status. Corporations and LLCs must also retain the beneficial owner list prepared under the previous law for ten years from commencement. The federal register does not replace your permanent company file.

Sarah’s advice
Add a transparency register check to every ownership or governance transaction. Keep the ownership chart, supporting evidence, verification date and filing confirmation together. This makes the next update much easier.

Is the register public, and does registration cost anything?

Competitors and the general public will not be able to browse this register freely. Access is reserved for designated authorities and authorised financial intermediaries or advisers carrying out statutory duties. “Transparency” does not mean that every corporation’s ownership becomes public.

Registration, amendments and deletion are free of charge. Fees may nevertheless apply to certain extracts, reminders, formal notices or decisions. Professional fees charged by an accountant or adviser for preparing the file are separate from official charges.

What are the consequences of non-compliance?

The control authority within the Federal Department of Finance can check whether information is accurate and complete and require corrections. Article 43 LTPM provides for a fine of up to CHF 500,000 for intentional breaches of the specified duties, including certain reporting or cooperation obligations.

This is a statutory maximum, not an automatic fine for every typing error. Document your checks, correct inconsistencies and respond to the authority’s requests. A declaration already provided to a bank does not remove these duties.

Prepare your filing with a clear company record

For most SMEs, start with three questions: who controls the company, which deadline applies and who will file? Once the answers are documented, arrange EasyGov access and gather the supporting records.

The reform applies federally. A company in Geneva therefore follows the same basic framework as a company in Vaud or Valais. More complex structures need additional attention, particularly where holding companies, foreign owners or control agreements are involved.

Swiss transparency register FAQ