Swiss transparency register takes effect: Is your company ready?

Switzerland’s new transparency regime is now in force, requiring Swiss companies to report their beneficial owners. The following key takeaways highlight the main obligations, deadlines and practical steps under Switzerland’s new transparency regime:

• New transparency regime now in effect: Switzerland’s Legal Entities Transparency Act and its implementing ordinance entered into force on 1 October 2026, introducing a non-public and centralised register for beneficial owners.
• Broad scope of application: The new rules generally apply to Swiss companies, certain foreign legal entities with a connection to Switzerland and certain trustees. Listed companies and several other categories of entities benefit from exemptions.
• Beneficial owners must be identified and verified: Companies must determine the individuals who ultimately control them, whether through direct or indirect participation, or other means of control.
• Extensive information must be reported: Required information includes personal details of beneficial owners, the nature of their control and, where applicable, the relevant participation band. Companies must keep the information up-to-date and retain supporting documentation for ten years after a person ceases to be a beneficial owner.
• Filing deadlines vary: Transitional deadlines for existing entities are staggered between 1 January 2027 and 1 October 2028, depending on the type of company, its audit status and whether the beneficial owners are already recorded in the commercial register. Newly incorporated companies must generally file within one month of registration.
• Commercial register changes can accelerate the deadline: The first amendment to a company’s commercial register entry after 1 October 2026 triggers in principle an obligation to submit the initial declaration within one month. Subsequent changes to registered information must also generally be reported within one month after the company becomes aware of them.
• Declarations will generally be filed via EasyGov: Companies must appoint an authorised person who registers and authenticates on the platform.
• Internal registers are no longer required, but must be retained: Companies no longer need to maintain a separate internal register of beneficial owners. Existing registers must nevertheless be kept until 1 October 2036, while the share register must continue to be maintained and updated.
• Non-compliance may have serious consequences: Wilful violations may result in fines of up to CHF 500,000. Repeated or unresolved breaches may also lead to the suspension of shareholder rights and, as a last resort, the dissolution and liquidation of the company.
• Companies should act now: Recommended steps include confirming whether the new regime applies, determining the relevant deadline, appointing an authorised person for the notifications, mapping the complete ownership and control structure, gathering the required documentation and establishing processes to monitor future changes.