Switzerland’s new Transparency Act and its implementing Ordinance introduce a centralized electronic register of beneficial owners, operated by the Federal Office of Justice, with reporting obligations taking effect on 1 October 2026 and short transitional deadlines for existing entities.

At a glance

• On 12 June 2026, the Federal Council published the Transparency Ordinance implementing the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (Transparency Act), which enters into force on 1 October 2026 and supersedes the current beneficial ownership identification rules.
• In-scope entities must identify their beneficial owners (BO), collect and document prescribed information, and report it electronically to the new Transparency Register operated by the Federal Office of Justice.
• The register will not be publicly accessible only certain Swiss authorities and AML-regulated financial intermediaries and advisors (for KYC purposes) may consult it.

Background

The Transparency Act was passed by the Swiss Parliament in 2025 and calls for a centralized electronic register of beneficial owners storing information on Swiss entities and certain foreign legal entities with a Swiss nexus. With the implementing Ordinance now published, the regime takes effect on 1 October 2026, replacing the beneficial ownership rules currently in force.

Key Obligations

• Who is in scope – Swiss entities such as SA/AG, Sàrl/GmbH, cooperatives, and SICAV/SICAF; foreign entities with a Swiss nexus (a registered branch, effective place of management, or Swiss real estate); and certain trustees. Listed entities (and those at least 75% owned by listed entities or public authorities), pension funds, Swiss associations, Swiss foundations, and Swiss sole proprietorships are excluded.
• Defining the beneficial owner – The BO is the natural person who ultimately controls the entity by holding, directly or indirectly, alone or in concert, at least 25% of its capital or votes, or who controls it by other means (e.g. appointing/removing over half the board, veto rights over key decisions, or other decisive influence).
• Collecting and documenting BO information – For each BO, entities must record the nature and extent of control plus full name, date of birth, nationality, municipality, postal code, and country of residence (with proof of identity where there is no Swiss social security number), keeping the information up to date and accessible in Switzerland.
• Reporting to the Transparency Register – The highest-ranking management board member (or board of directors) must report the information electronically; the task may be delegated, but ultimate responsibility remains with the entity.
• Duties of shareholders and BOs  – Controlling shareholders and beneficial owners must supply the relevant information to the entity within one month of control arising, and report any change within one month.

Impact and Action Required

Swiss entities should already have identified their beneficial owners under the current GAFI rules, but they must now verify that those persons also qualify as BOs under the Transparency Act, that all required information is properly recorded, and that they are ready to report once the register opens. Foreign entities with a Swiss nexus warrant particular attention, as many may never have assessed their beneficial ownership under Swiss law and must also designate a Swiss representative or service address. With short transitional deadlines, all in-scope entities should be prepared to report promptly once the register becomes operational.

Timeline

The regime enters into force on 1 October 2026; new Swiss entities must report within one month of commercial register registration, while existing entities face transitional deadlines running from three to six months after entry into force (and up to two years where their BOs are already recorded in the commercial register as members or corporate bodies).