Switzerland’s Transparency Register and Anti-Money Laundering Reforms Take Effect
As of 1 October 2026, Switzerland has brought into force a federal register of beneficial owners and a revised Anti-Money Laundering Act. Together, the measures widen the information available to authorities and extend compliance duties to selected advisory services.
A new register goes live
Switzerland’s Federal Council has put two connected laws into force: the Federal Act on the Transparency of Legal Persons and the Identification of Beneficial Owners (TLPA) and a partial revision of the Anti-Money Laundering Act (AMLA). Parliament approved both measures on 26 September 2025. The Federal Council set 1 October 2026 as their start date, giving affected businesses and authorities time to prepare. The new framework is intended to close gaps in the country’s controls against money laundering and terrorist financing and to support the next Financial Action Task Force evaluation of Switzerland, scheduled for 2027–2028. 1 3
The centrepiece is a federal register of beneficial owners, maintained by the Federal Office of Justice. Its purpose is to give competent authorities faster access to reliable, current information about who ultimately owns or controls a company. A control unit within the Federal Department of Finance is tasked with checking the accuracy, completeness and currency of the data. 1 2
The register is not open to the general public. Access is limited to designated authorities and, subject to the law’s conditions, financial intermediaries and advisers covered by the AMLA when they need the data to carry out their due diligence. That design adds a central source for scrutiny without creating an unrestricted public directory of personal ownership data. 2 3
Who must identify and report beneficial owners?
The TLPA covers key Swiss legal forms, including companies limited by shares, limited liability companies, cooperatives and certain investment vehicles. Some foreign entities also fall within its reach if they have a Swiss-registered branch, are effectively managed from Switzerland, or own or acquire Swiss real estate within the statutory definition. Trustees with a Swiss connection have specific obligations as well. Listed entities, certain pension institutions and entities at least 75% owned by public authorities are among the exemptions. 2
A beneficial owner is a natural person who ultimately controls a company. The main test is direct or indirect ownership of at least 25% of capital or voting rights, alone or together with others. Control through other means can also qualify. If no individual meets those tests, the law identifies the most senior member of the executive body as the fallback beneficial owner. 2
Covered companies must identify and verify the relevant person, record identifying details and information about the kind and extent of control, and submit the required information to the register. They must keep the supporting records up to date and available in Switzerland. The law requires those records to be retained for ten years after the person stops qualifying as a beneficial owner. 2
Existing entities do not all face the same initial filing deadline. The transition periods start on 1 October 2026 and vary according to legal form and audit status; some can extend for up to two years. Newly formed entities and reportable changes are subject to separate notification deadlines, so companies should check the rules for their specific category rather than assume a single universal date. 1 4 The Federal Council also said that provisions concerning notaries employed under public law were postponed so cantons could adapt their legislation. 1
The AMLA reaches selected advisory work
The revised AMLA expands the scope of regulated activity beyond traditional financial intermediaries. Certain professional advisory services connected with financial transactions are now covered, including specified work involving real-estate transactions and the establishment or structuring of legal entities. The updated rules require covered advisers to identify clients and beneficial owners, document relevant information and apply due diligence proportionate to risk. The Federal Council said it introduced thresholds to define the newly covered professional activity more clearly. 1 3
This extension is not a blanket rule for every lawyer, consultant or property professional. The statutory scope is tied to defined services and transactions, and exemptions apply to specified situations. Advisers need to assess what they actually do, who they serve and whether the activity falls within the law. The reform also brings the register into day-to-day compliance work: eligible intermediaries and advisers can consult relevant records as part of their checks, while discrepancies may require clarification and further action under the applicable rules. 3 5
What changes for companies and gatekeepers?
For businesses, the main operational task is to map ownership and control all the way to the natural persons behind the entity. A simple share register may not tell the whole story where voting arrangements, indirect holdings or other forms of control are involved. Companies should be able to substantiate the information they report and maintain a process for updating it when ownership or control changes. 2 4
For banks and other regulated intermediaries, a central register can make it easier to compare a customer’s declared ownership with information recorded elsewhere. The register does not replace customer due diligence or remove the need to investigate inconsistencies. Rather, it adds another source that can support those checks and make concealed or complicated control structures harder to overlook. 3 5
The system’s effectiveness will depend on more than the creation of a database. The data must be accurate, kept current and checked against other information. Authorities and reporting entities must also be able to follow up when a filing is incomplete or when ownership cannot be established with confidence. The coming transition period will test how well these elements work across a large range of corporate structures.
Closing Thoughts
The reform marks a meaningful change in how Switzerland records corporate control. Its central promise is straightforward: competent authorities and regulated gatekeepers should be able to identify the people who ultimately stand behind legal entities more quickly and with better-quality information. The approach pairs a shared federal record with company-level duties to verify and maintain that information.
The balance is deliberate. Switzerland is increasing traceability while keeping the register closed to general public browsing. Whether that balance builds trust will depend on the quality of implementation, consistent follow-up and clear guidance for companies facing different reporting timetables.
How does this play out in reality?
Consider a Swiss company whose shares are held through several entities. Under the new framework, the company must look beyond the immediate shareholder and identify the natural person—or people—who ultimately hold at least 25% of the capital or voting rights, or otherwise exercise control. It must check the relevant details, report them as required and keep evidence on file. A bank serving the company may then use its permitted access to compare register information with its own customer records and investigate material inconsistencies.
A foreign company can also be caught by the rules if it has the relevant Swiss connection, such as a local branch or Swiss real estate. Separately, an adviser arranging a covered transaction may have AMLA duties even if the adviser is not a bank. The practical result is a wider set of actors responsible for understanding where control lies and how money moves.
Why does this make a difference?
Opaque ownership can make it harder to detect criminal proceeds, sanctions evasion, corruption or terrorist financing. A central register, better recordkeeping and due diligence duties for selected advisers give authorities and compliance teams additional ways to test who controls a company and whether the declared story is credible. These measures do not guarantee that illicit finance will be stopped, but they can make concealment more difficult and investigations more efficient when reliable information is available.
The real measure of success will be how accurately companies report, how effectively the audit unit checks the data and how consistently authorities and AMLA-supervised businesses act on discrepancies. As the transition periods unfold, those practical outcomes will show whether the new framework strengthens Switzerland’s defences as intended.
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