Switzerland’s transparency register began operating on 1 October2026. For affected companies, the immediate task is to establish their filingdeadline and check that the ownership information behind the report iscomplete. Existing entities have different transition periods, and a change toa Swiss company’s commercial register entry can bring its deadline forward.
The launch turns the beneficial ownership reformsinto a practical administration task. Boards and company administrators shouldnow know who will prepare the report, who will check it and whether the filingaccess is ready.
Check each entityin the structure
The reporting requirement covers Swiss companies limited by shares(AGs), limited liability companies (GmbHs), cooperatives and specifiedinvestment vehicles. Foreign legal entities can also be caught where they havea registered Swiss branch, are effectively managed in Switzerland, or own Swissreal estate or acquire it in a transaction covered by the Lex Koller rules.
There are exclusions, including listed companies and certainsubsidiaries. Swiss foundations and associations are outside the reportingrequirement, although they may form part of the ownership chain of a companythat must report. The official scope guidance should therefore bechecked for each entity. For cross-border structures, obtain independent legalor tax advice where the Swiss connection is unclear.
Establish thedeadline before relying on a transition period
For existing Swiss entities, the official guidance sets out transition periodsrunning from 1 October 2026. Unless the special two-year rule applies, themaximum periods are:
• Three months for AGs subject toan ordinary audit.
• Four months for other companiessubject to an ordinary audit.
• Five months for AGs not subjectto an ordinary audit.
• Six months for other companiesnot subject to an ordinary audit and other covered legal persons.
A two-year period applies where all beneficial owners are alreadyentered in the commercial register as members or an organ. However, the firstcommercial register change after commencement can trigger a one-month filingwindow, running from publication in the Swiss Official Gazette of Commerce.Check this before relying on the longer period.
Existing foreign legal entities in scope generally have six months.New companies generally report within one month of incorporation in thecommercial register; foreign entities newly entering scope also face aone-month period. A property acquisition can require registration sooner. Thesedistinctions belong in the filing calendar for each entity.
Verify the peoplebehind the ownership chain
A beneficial owner must be a natural person. The control test includes holding at least 25 percent of capital or voting rights, directly or indirectly, alone or actingtogether with others. Control through other means, including contractualarrangements, also matters.
A shareholder list is therefore a starting point. Where a holdingcompany or trust sits in the structure, trace the chain to the people whoultimately control it. Collect the identity and residence information neededfor the report, with evidence supporting the nature and extent of control.
Check names and dates against official documents. The registerauthority has highlighted errors such as reversed first names andsurnames and incorrect birth dates. These can prevent identity verification andlead to a chargeable correction request. Resolve discrepancies while preparingthe report.
Arrange EasyGovaccess early
Reports can be submitted free of charge through EasyGov. The registration process uses a personal AGOV login linked to thereporting entity’s Swiss identification number. Authorisation and validationcan take several days, so access should be arranged before the filing deadlineapproaches.
An existing corporate administration mandate does not establish thatthe person preparing the report already has platform access. Confirm theauthorised user and test the connection for each entity. The alternative routethrough cantonal commercial register offices is not yet available.
Build a processfor changes after filing
The first report is followed by ongoing work. The company must keepits information current and report relevant changes within one month oflearning of them. Assign someone to assess changes in ownership or control andretain evidence of the reports submitted. Intentional breaches of specifiedreporting and information duties can attract fines of up to CHF 500,000 under Article 43.
The register is non-public. Although reporting is open, theauthority says register searches and discrepancy reports are not yetavailable. Companies should continue their own verification workrather than assume that another party can already check their submissionthrough the register.
Alpadis’Swiss team supports company administration and international structures. We canhelp clients organise their corporate records and coordinate the administrativework needed as reporting obligations change, working with independent legal andtax advisers where specialist assessment is required.
