Marcus Altenburg, Published
Swiss Transparency Register: reporting deadlines for existing companies
The Federal Act on the Transparency of Legal Persons (TJPG) has been in force since 1 October 2026. Existing Swiss companies must report their beneficial owners to the federal Transparency Register within one month of their first commercial register change after that date, but no later than fixed deadlines between 31 December 2026 and 31 March 2027, depending on the company type.
The TJPG and the Transparency Register
The Federal Act on the Transparency of Legal Persons and the Identification of Beneficial Owners (TJPG) was adopted by Parliament on 26 September 2025. The Federal Council decided on 12 June 2026 to bring it into force on 1 October 2026. It has been in force since 1 October 2026. The Act creates a federal Transparency Register of beneficial owners. The register is not public. The text of the Act on Fedlex sets out the reporting duties in detail.
Deadlines for existing companies
Existing Swiss companies report within one month of the first change to their commercial register entry made after 1 October 2026, but no later than the deadlines below. The deadlines as of November 2026 are:
| Company type | Deadline |
|---|---|
| Companies limited by shares (AG) subject to an ordinary audit | 31 December 2026 (three months) |
| Other companies subject to an ordinary audit | 31 January 2027 (four months) |
| AGs that do not meet the criteria for an ordinary audit | 28 February 2027 (five months) |
| All other companies and legal persons, for example a GmbH owned through a holding company | 31 March 2027 (six months) |
A company formed after 1 October 2026 reports its beneficial owners within one month of its registration in the commercial register. Any change to the reported facts must be reported within one month of the company becoming aware of it.
Special cases and longer periods
If all beneficial owners are already entered in the commercial register as members or as officers (bodies), the company has two years from 1 October 2026, i.e. until the end of September 2028. This typically covers a GmbH whose members are all natural persons, and an AG whose only shareholder sits on the board and is entered in the register. Foreign legal persons that fall under the Act report within six months of 1 October 2026, i.e. by 31 March 2027.
Enforcement and sanctions
When a company amends its register entry during the transitional period, the cantonal commercial register office reminds it of the reporting duty. After the deadlines, the federal authority checks whether the company has reported and orders it to do so if it has not. Intentional breaches of the reporting duties, or false information, are punishable by a fine of up to CHF 500,000. Shareholders and members must tell the company about changes to their information within one month.
Practical preparation
The company needs current identification data on each beneficial owner before it can file. A beneficial owner is the natural person who controls 25% or more of capital or votes, or controls the company in another way. Further detail is set out in our guide to the Transparency Register.
Goldblum and Partners supports companies in preparing the identification data and filing the report within the applicable deadline through its corporate secretarial service.
Frequently asked questions.
01When must an existing Swiss company report its beneficial owners?
02Is the Transparency Register public?
03What are the sanctions for not reporting?
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