As a result, numerous entities, as well as certain beneficial owners, will be subject to new identification, documentation and reporting obligations. An initial overview is available here: Swiss Transparency Register – New Regime, New Obligations.
What does this mean for you? Please assess whether you need to take any action based on the overview below.
(A) SIMPLIFIED ASSESSMENT FRAMEWORK
Step 1 – Scope of Application
In relation to a Swiss entity or a foreign entity with a connection to Switzerland, are you (i) the highest-ranking member of the governing body, (ii) the holder of company interests carrying control rights, or (iii) a beneficial owner?
➔ If yes, proceed to Step 2.
➔ If no, you are not within the scope of the LETA.
Step 2 – Exemptions
Does one of the following exemptions apply to you?
The legal entity:
(a) is a listed company or a subsidiary of a listed company that is directly or indirectly owned by more than 75%;
(b) is an occupational pension institution (or a comparable supervised pension institution); or
(c) is at least 75% directly or indirectly owned by the public sector (public authorities).
➔ If no, proceed to Step 3.
➔ If yes, you are exempt from the scope of application of the LETA.
Step 3 – Obligations
Under the LETA, the following obligations apply depending on your role:
(a) As the highest-ranking member of the governing body:
Identification of the beneficial owner(s), documentation of the relevant information, and ongoing reporting of changes to the Transparency Register.
(b) As the holder of company interests carrying control rights:
Reporting of the beneficial owner(s), submission of the required information and supporting documentation, and ongoing reporting of changes to the company.
(c) As a beneficial owner (or as another affected third party):
Reporting of the beneficial owner(s), submission of the required information and supporting documentation, and ongoing reporting of changes to the shareholder(s) and/or the company.
(B) REPORTING DEADLINES
The shortest reporting deadlines are generally one month:
- for companies newly registered in the Commercial Register on or after 1 October 2026: from the date of registration
- in the event of relevant changes to an entry in the Commercial Register: from the date of the change
- in the event of changes to reportable information: from the date such change becomes known.
For existing legal entities, the following extended transitional periods apply:
- corporation (AG/SA), subject to an ordinary audit: 4 January 2027
- other companies, subject to an ordinary audit: 1 February 2027
- corporation (AG/SA), not subject to an ordinary audit: 1 March 2027
- other companies, not subject to an ordinary audit: 1 April 2027
- companies whose beneficial owners are already all registered in the Commercial Register as shareholders or corporate officers: 2 October 2028
(C) FORM OF REPORTING
Standard procedure: Reports are submitted to the Transparency Register via EasyGov.swiss, either by the company itself or by a person authorized by the company.
Alternative: A report may be submitted to the competent Commercial Register if it is confirmed that all beneficial owners are already registered in the Commercial Register as shareholders or corporate officers.
There remain a number of aspects that still require clarification. The relevant practice will need to develop over time, and we continue to closely monitor developments. In any event, we will be pleased to assist you where required and remain available at any time to discuss your specific circumstances on a case-by-case basis.