On 1 October 2026, Switzerland’s Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners came into force, and a central register of beneficial owners started work, run by the Federal Office of Justice. Most Swiss companies must now tell the state, once and then after every change, which people ultimately control them. On the same day, revised anti-money-laundering rules brought some lawyers and advisers under due-diligence duties.
The European Union and the United Kingdom have had such registers for years. For a country long associated with discretion, it is a real change, and for families that hold assets through Swiss companies it is a new duty.
What a beneficial-ownership register is
The legal owner of a company is whoever appears in the share register. That can be another company, a trust or a nominee. The beneficial owner is the human being at the top of the chain who really controls the company or benefits from it. A beneficial-ownership register records those people, so that authorities can see through layers of holding companies and trusts.
A simple example: a Swiss family holding company is owned by three siblings, each through their own small company. The holding company must report the three siblings, not the three small companies.
Who must report in Switzerland
According to the Federal Office of Justice, the duty applies to Swiss companies limited by shares (AG), partnerships limited by shares, limited liability companies (GmbH), cooperatives, and certain investment companies and partnerships. Foreign legal entities must also report if they have a Swiss branch in the commercial register, are actually managed from Switzerland, or own Swiss real estate.
Exempt are listed companies and their subsidiaries more than 75% owned by listed companies, pension institutions, and entities more than 75% owned by public bodies. The top member of the company’s governing body is responsible for filing, which is free and done online through the federal EasyGov platform.
The 25% test
A person controls a company if they ultimately hold at least 25% of its capital or votes, directly or indirectly, alone or together with others, or if they control it in another way, for example through a contract. A beneficial owner is always a natural person. If nobody meets the test, the top member of the management body is reported instead, according to Grant Thornton and Härting.
Foundations and trusts
Foundations are not covered by the new law, according to the official questions and answers; some early law-firm summaries said otherwise. A foundation can still appear in the control chain of a company that must report, and special rules then apply.
A trust is not a legal entity and has no reporting duty of its own, law firm Kendris notes. But if a trust holds a stake in a Swiss company, that company must report the people behind the trust. The official guidance says control can run through trusts.
Who can see it, and the deadlines
The register is not public. Only the control body at the Federal Department of Finance, authorities named in the law, and financial intermediaries and advisers covered by anti-money-laundering law can use it, and only for their legal tasks. Companies cannot browse it.
The Federal Office of Justice says first-filing deadlines run from one month to two years, depending on the type of entity. Kendris expects most existing companies to have three to six months. Grant Thornton dates those deadlines between 1 January and 1 April 2027, and says a company that changes its commercial-register entry earlier must file within one month of that change. Every later change must be reported within one month. Intentional breaches of the reporting duties can bring fines of up to CHF 500,000, according to Grant Thornton.
Lawyers and advisers come under anti-money-laundering rules
The Federal Council says the revised rules introduce due-diligence duties for certain high-risk advisory work. According to Härting, this covers lawyers and notaries when they design structures, set up or administer companies, act as directors or nominees, or provide a registered address. Pure legal advice and court work remain exempt. Covered advisers must identify their clients and beneficial owners, keep records and report suspicions to the authorities.
How this compares with the EU and the UK
- United Kingdom. Since 2016, UK companies have had to record their “people with significant control,” broadly anyone with more than 25% of the shares or votes, or the right to appoint most of the board. The information goes to Companies House, and the register is public.
- European Union. EU law requires national registers. In 2018 it opened them to the general public, but on 22 November 2022 the EU Court of Justice struck down that general public access as a serious interference with privacy and data protection. Several countries, including Luxembourg and the Netherlands, then restricted access.
Switzerland chose a non-public register from the start, a choice Härting notes was criticised during consultation.
A fair caveat
The register is new, and some functions are not yet live, according to the Federal Office of Justice. Deadlines depend on each entity’s facts, and the penalty figure comes from one adviser’s summary of the law. Guidance may still change.
Five lessons to take away
- Ownership is about people, not paper. Every chain must end with named individuals.
- Holding companies and trusts do not hide the top. The company must look through them.
- Non-public does not mean secret. Authorities, banks and some advisers can see the data.
- Mind the clock. Deadlines differ by entity, and every change must be reported within a month.
- Your advisers have new duties too. Expect more questions when they set up or run a structure.
Questions to bring to your advisors
Does each of our Swiss companies, and any foreign company we manage from Switzerland or that owns Swiss property, know who its beneficial owners are under the 25% test? Which deadline applies to each, and who on the board files and checks the data? How will a trust or foundation in our chain be treated? These are questions to bring to your lawyers and tax advisors, not advice.