No country is more synonymous with financial secrecy than Switzerland. For a century, Swiss banking secrecy was a brand — a legal guarantee of confidentiality that made the country the world's pre-eminent destination for cross-border wealth. Even after the automatic exchange of tax information eroded that secrecy for foreign account holders, and even after bearer shares were abolished, Switzerland remained at the very top of the global secrecy rankings: it sits second on the Financial Secrecy Index, behind only the United States.
One thing Switzerland conspicuously never had was a central register of beneficial owners. Where the EU built central registers, where the UK built the PSC register, and where the offshore jurisdictions built their own systems, Switzerland relied on a fragmented patchwork — beneficial-ownership information scattered across cantonal commercial registers, banks, and fiduciaries, identified under anti-money-laundering rules that dated to 2015 but never consolidated into a single searchable source. The Financial Action Task Force noticed, and rated Switzerland only "partially compliant" on beneficial-ownership transparency for precisely that reason.
That gap is now being closed. On 26 September 2025, the Swiss Parliament adopted the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners — known by its German abbreviation TJPG, and rendered by various firms as LETA or the Legal Entities Transparency Act. For the first time in its history, Switzerland will operate a central federal register of beneficial owners. Alongside it, Parliament revised the Anti-Money Laundering Act to pull a new category of professionals — advisors such as lawyers and notaries — into the AML perimeter.
The register is not public. Learning from the EU's experience — where the Court of Justice struck down public registers in 2022 — Switzerland built a closed register from the outset, accessible only to competent authorities and to financial intermediaries subject to the AML law. The Act is expected to enter into force in the second half of 2026, with the timing deliberately aligned to Switzerland's next FATF mutual evaluation.
This guide explains how the new Swiss regime actually works: the TJPG and the Transparency Register, the 25% threshold, who is in and out of scope (the foundations carve-out is significant), the new obligations on advisors, the penalties, the timeline, and the workflow for verifying a Swiss beneficial owner when the register is closed to you.
- The Swiss regime in 2026: the end of the register gap
- From banking secrecy to a transparency register
- The 25% threshold and the control test
- The Transparency Register: closed, federal, FOJ-run
- Who is in scope — and the foundations carve-out
- The AMLA revision: advisors enter the perimeter
- How to verify a Swiss UBO: step-by-step workflow
- Penalties: the CHF 500,000 reporting offence
- Recent and upcoming changes: 2025–2027
- Cross-border implications for EU, UK, and US teams
- Switzerland in context: how it compares
- Practical takeaways for compliance teams
- Frequently asked questions
1. The Swiss regime in 2026: the end of the register gap
The Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) was adopted by the Swiss Parliament on 26 September 2025. It establishes, for the first time in Swiss history, a central federal register of beneficial owners — the Transparency Register — and consolidates beneficial-ownership rules that had previously been spread across the Code of Obligations, the tax administrative-assistance legislation, and the Criminal Code.
Three things define the new regime:
- A central register, where there was none. Switzerland's beneficial-ownership information previously lived in a fragmented patchwork — cantonal commercial registers, the internal records that banks and fiduciaries keep under the AML law, and company share registers. The TJPG creates a single federal Transparency Register, maintained by the Federal Office of Justice, that competent authorities can query directly.
- Closed by design. The register is not public. Switzerland built it as a closed register accessible only to authorities and to AML-subject financial intermediaries — deliberately sidestepping the public-access model the EU's top court found unlawful in 2022.
- A parallel reach into the advisory professions. The accompanying revision of the Anti-Money Laundering Act extends due-diligence obligations to "advisors" — lawyers, notaries, and fiduciaries performing certain structuring services — a category that previously sat largely outside the AML perimeter.
2. From banking secrecy to a transparency register
To understand why this reform matters, it helps to see it as the latest step in a two-decade unwinding of Swiss financial secrecy — each step forced by international pressure.
For most of the twentieth century, Swiss banking secrecy was codified and near-absolute. The erosion came in stages: the adoption of the automatic exchange of financial-account information (AEOI) with partner jurisdictions progressively stripped confidentiality from foreign account holders; the abolition of bearer shares removed one of the classic tools of anonymous ownership; and successive FATF evaluations kept the pressure on. But through all of it, Switzerland never built the one thing FATF Recommendation 24 increasingly expected of every serious financial centre — a central, authority-accessible register of who ultimately owns and controls legal entities.
FATF rated Switzerland only "partially compliant" on beneficial-ownership transparency, specifically because it lacked a central register and relied on fragmented sources across cantons, banks, and fiduciaries. For a country whose financial centre depends on its international credibility, a sub-par FATF rating on beneficial ownership is a commercial risk, not just a technical one. The TJPG is, in large part, Switzerland's answer — and its timing is deliberately aligned with the next FATF mutual evaluation so the country can demonstrate a working register when the evaluators arrive.
The result is a jurisdiction making a genuine transition: from the global archetype of financial secrecy toward a documented, register-based transparency regime — while carefully keeping the register itself closed to the public, preserving a degree of the confidentiality that has always been part of the Swiss proposition.
3. The 25% threshold and the control test
Under Article 4 of the TJPG, a beneficial owner is a natural person who ultimately controls a legal entity. Control is established in one of three ways, assessed in order:
- The 25% test. A natural person who holds, directly or indirectly, at least 25% of the capital or voting rights of the entity.
- Control by other means. Where no one meets the 25% test, a person who exercises effective control over the entity by other means — through shareholder agreements, veto rights, or other contractual or financial arrangements.
- The senior-management default. Where no natural person can be identified under either test, the entity must register the most senior member of its management body — typically the chair or managing director — as the beneficial owner.
The 25% threshold aligns Switzerland with the existing definition in the Swiss Code of Obligations (Article 697j), the FATF Recommendation 24 baseline, the EU's AMLR, the UK PSC regime, and the offshore and Asian regimes — Cayman, Singapore, and Bermuda all sit at 25%. For compliance teams running cross-jurisdictional CDD, Swiss data calibrates naturally to a 25% home regime. The notable low-threshold outlier remains the BVI at 10%.
The TJPG treats the 25% figure as illustrative of control rather than a hard cut-off. Control can be established through means other than a simple shareholding percentage — the second test (control by other means) is designed to catch exactly the structures where formal ownership is fragmented or held through nominee-style arrangements but real control rests elsewhere. For complex Swiss holding structures, the control test, not the arithmetic threshold, is often the operative question.
4. The Transparency Register: closed, federal, FOJ-run
The Transparency Register is the structural centrepiece of the reform — and its design choices are deliberate.
It is maintained by the Federal Office of Justice (FOJ), leveraging the existing infrastructure and expertise of the commercial-register authorities. Data quality is overseen by a supervisory and audit unit within the Federal Department of Finance. In-scope entities must identify their beneficial owners and report the prescribed information — and, critically, keep it current, updating the register when ownership or control changes.
One subtle but important design choice: the Swiss Parliament explicitly rejected any presumption that the register is accurate. The register is a source of information, not a guarantee of truth. If a financial intermediary discovers a discrepancy between what the register says and the information it holds from its own due diligence, it is obliged to report that discrepancy. For compliance teams, this is a clear signal: the Swiss register is to be used as a cross-check, not relied on as the definitive answer — the same posture the EU's AMLR takes toward member-state registers.
5. Who is in scope — and the foundations carve-out
The TJPG applies broadly to Swiss legal entities, with several significant exemptions that compliance teams need to understand because they shape what data will and will not exist in the register.
| Entity type | Status under the TJPG |
|---|---|
| Corporations limited by shares (AG / SA) | In scope. |
| Limited liability companies (GmbH / Sàrl) | In scope. |
| Cooperatives | In scope. |
| SICAVs, SICAFs, collective investment vehicles | In scope. |
| Foreign entities with a Swiss nexus (Swiss branch, effective administration in Switzerland, or owning Swiss real estate) | In scope. |
| Trustees domiciled in or administering trusts from Switzerland | In scope — except trustees already subject to the AML law. |
| Listed companies and their >75%-held subsidiaries | Exempt — ownership already transparent under securities law. |
| Occupational pension institutions | Exempt. |
| Foundations and associations | Excluded — by deliberate Parliamentary decision. |
Two scope features matter especially for cross-border structures. First, trustees domiciled in Switzerland or administering trusts from Switzerland are in scope — except where they are already subject to the AML law — which pulls a slice of the Swiss trust-and-fiduciary industry, long a pillar of the country's wealth-management role, into the register for the first time. Second, the Act reaches foreign legal entities with a Swiss nexus: a registered Swiss branch, effective administration (actual management) conducted in Switzerland, or ownership of Swiss real estate. A company incorporated abroad but genuinely run from, or holding property in, Switzerland cannot sidestep the regime by virtue of its foreign incorporation.
The most consequential — and most debated — exemption is for foundations and associations. Parliament deliberately excluded them from the register's identification and registration regime. The committee rationale was twofold: that a foundation has "independent assets" and therefore "no beneficial owner in the actual sense," and that bringing them in would impose an additional burden on the Swiss economy. For compliance teams, this is a genuine gap to be aware of: a Swiss foundation — a structure that can hold and control significant assets — will not appear in the Transparency Register, and beneficial-ownership-style information about it must be sought through other means.
Beyond the foundations carve-out, the Swiss Parliament made two notable decisions to keep the regime lighter than some international models. It declined to introduce any transparency or reporting requirements for nominee directors and nominee shareholders — so nominee arrangements are not separately flagged, unlike in Singapore's 2025 reforms. And it kept the register closed to the public entirely. Both choices reflect a characteristic Swiss balance between meeting the FATF standard and limiting the administrative and privacy burden on legitimate business.
6. The AMLA revision: advisors enter the perimeter
Running in parallel with the TJPG is a revision of the Anti-Money Laundering Act (AMLA) — and it contains one of the most significant changes in the whole package: the extension of AML due-diligence obligations to advisors.
Historically, the Swiss AMLA applied principally to financial intermediaries — those who professionally handle assets belonging to others (banks, asset managers, fiduciaries acting as such). The revision extends due-diligence obligations to advisors — including lawyers and notaries — when they perform certain advisory and structuring activities deemed to pose an increased money-laundering risk, such as creating, managing, or administering companies and other structures.
The operational consequences are material:
- Advisors must perform their own due diligence. A lawyer, notary, or fiduciary helping to set up or structure a company is now, for those activities, a subject of the AML law with identification and verification obligations of their own.
- Discrepancy reporting. Where an advisor or financial intermediary discovers a discrepancy between a client's own records and the Transparency Register, they are obliged to report it — closing the loop between the register and the professionals who interact with it.
- A narrowing of the traditional advisory shield. The change reflects an international trend — visible in the EU's AMLR too — of pulling the professional enablers of corporate structures into the AML perimeter rather than leaving them outside it.
7. How to verify a Swiss UBO: step-by-step workflow
In this illustrative chain, two Swiss layers sit beneath a Luxembourg parent. Both Swiss layers will hold Transparency Register entries once the TJPG is in force, but those are closed to a foreign bank. The Luxembourg layer is on the Luxembourg RBE, accessible via the legitimate-interest pathway under the EU regime. Where the chain leads to a transparent jurisdiction upstream, the UBO is resolvable without access to the Swiss register. Where the chain stays within Switzerland — or runs through an excluded foundation — contractual disclosure under onboarding terms is the operational route.
8. Penalties: the CHF 500,000 reporting offence
The TJPG backs its reporting obligations with criminal fines, enforced through an inspection body responsible for the register's integrity.
The enforcement model rests on two pillars working together: the inspection body that polices the register directly, and the discrepancy-reporting duty imposed on financial intermediaries and advisors. A Swiss entity that under-reports its beneficial owners is exposed not only to the inspection body, but to the prospect that its own bank or advisor — now obliged to report discrepancies — flags the gap. That combination is designed to make the register self-correcting over time.
9. Recent and upcoming changes: 2025–2027
10. Cross-border implications for EU, UK, and US teams
Threshold alignment — no reconciliation needed
Switzerland's 25% threshold aligns with the EU AMLR, UK MLR, FATF Recommendation 24, and the major offshore and Asian regimes. CDD teams do not face threshold reconciliation work on Swiss data, unlike the BVI's 10% regime.
Switzerland is not in the EU — but the package mirrors the EU's direction
Switzerland is neither an EU nor an EEA member, so the EU's AMLR and AMLD6 do not apply to it. But the TJPG and AMLA revision are explicitly designed to align Switzerland with FATF standards and EU/EEA practice. The result is convergence: a closed central register, a 25% threshold, advisor obligations, and a no-presumption-of-accuracy posture that mirror the EU's own direction of travel. For a compliance team, Swiss and EU beneficial-ownership data are becoming more comparable, not less.
The foundations gap is a cross-border watch-point
Because Swiss foundations are excluded from the register, a structure that routes control through a Swiss foundation will not surface a beneficial owner in the Transparency Register. For EU, UK, and US teams applying their own beneficial-ownership rules — which may well require looking through a foundation to a controlling person — this is a point where the Swiss register will not do the work, and independent analysis or contractual disclosure is required.
Sanctions
Switzerland is not an EU member and sets its own sanctions policy through the State Secretariat for Economic Affairs (SECO), though it has aligned with EU sanctions packages in recent years, including those relating to Russia. For compliance teams, Swiss counterparties should be screened against the home-jurisdiction lists (OFAC SDN, EU Consolidated, UK HMT) as primary controls, with awareness that Switzerland's autonomous implementation can differ at the margin from the EU regime it generally mirrors.
11. Switzerland in context: how it compares
Switzerland's new regime is best understood next to the other major closed-register and European systems compliance teams encounter. For the full picture across every jurisdiction, see the global UBO regulations index.
12. Practical takeaways for compliance teams
| Question | 2026 answer |
|---|---|
| Does Switzerland have a beneficial-ownership register? | Yes — for the first time. The central Transparency Register under the TJPG, adopted 26 September 2025, expected in force in the second half of 2026. |
| Is it public? | No. Access is restricted to competent authorities and AML-subject financial intermediaries. There is no public or legitimate-interest tier. |
| What's the threshold? | 25% of capital or voting rights, directly or indirectly; or control by other means; or, failing both, the most senior manager. |
| Who maintains it? | The Federal Office of Justice (FOJ), with data-quality oversight by an inspection body in the Federal Department of Finance. |
| What's excluded? | Listed companies and >75%-held subsidiaries, pension institutions, and — significantly — foundations and associations. Nominee arrangements are not separately flagged. |
| What changed for advisors? | The AMLA revision pulls advisors (lawyers, notaries, fiduciaries) into the AML perimeter for certain structuring activities, with their own due-diligence and discrepancy-reporting duties. |
| Can I rely on the register? | No — it carries no presumption of accuracy. Use it as a cross-check; financial intermediaries must report discrepancies. |
| What's the penalty? | Up to CHF 500,000 for an intentional breach of the reporting duty or false statements; up to CHF 100,000 for ignoring inspection-body orders. |
13. Frequently asked questions
Does Switzerland have a beneficial-ownership register?
Yes, for the first time. On 26 September 2025 the Swiss Parliament adopted the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG), which establishes a central federal Transparency Register of beneficial owners maintained by the Federal Office of Justice. It is expected to enter into force in the second half of 2026. Before this, Switzerland relied on a fragmented system of cantonal commercial registers and the internal records of banks and fiduciaries, with no central register.
Is the Swiss Transparency Register public?
No. The register is closed. Access is restricted to competent authorities — such as the FIU (MROS), tax authorities, and law enforcement — and to financial intermediaries subject to the Anti-Money Laundering Act, under defined conditions. Unlike the EU's pre-2022 model, the Swiss register was never designed for public access, and there is no journalist or legitimate-interest pathway.
What is the Swiss beneficial-ownership threshold?
Under Article 4 of the TJPG, a beneficial owner is a natural person who holds at least 25% of the capital or voting rights of an entity, directly or indirectly, or who exercises control by other means. If no natural person can be identified under either test, the entity registers its most senior manager as the beneficial owner. The 25% threshold aligns with the Swiss Code of Obligations, FATF Recommendation 24, the EU, and the UK.
What is the TJPG / LETA?
They are different abbreviations for the same law: the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, adopted on 26 September 2025. "TJPG" derives from the German name (Transparenzregistergesetz); some firms render it in English as "LETA" (Legal Entities Transparency Act) or "TLEA." It establishes Switzerland's first central Transparency Register and is accompanied by a revision of the Anti-Money Laundering Act.
Are Swiss foundations covered by the register?
No. The Swiss Parliament deliberately excluded foundations and associations from the Transparency Register's identification and registration regime. The committee rationale was that a foundation has "independent assets" and therefore "no beneficial owner in the actual sense," and that including them would burden the Swiss economy. For compliance teams this is a genuine gap: a Swiss foundation will not appear in the register, so beneficial-ownership-style information about it must be obtained by other means.
How does the AMLA revision affect advisors?
The parallel revision of the Anti-Money Laundering Act extends due-diligence obligations to advisors — including lawyers, notaries, and fiduciaries — when they carry out certain advisory and structuring activities (such as creating or managing companies and structures) deemed to pose an increased money-laundering risk. Previously the AMLA applied principally to financial intermediaries who handle others' assets. Advisors now have their own identification, verification, and discrepancy-reporting duties for those activities.
When does the Swiss regime take effect?
The TJPG and the AMLA revision were adopted on 26 September 2025. The Federal Council presented a draft implementing ordinance on 15 October 2025, with a consultation running to 30 January 2026. Entry into force is expected in the second half of 2026, on a date set by the Federal Council, with transitional periods for existing entities. The timing is aligned with Switzerland's next FATF mutual evaluation in 2027.
Can a foreign bank access the Swiss register?
Not directly. The register is closed to foreign banks and the general public. A foreign bank verifying a Swiss counterparty should confirm the entity in the public commercial register (Zefix), request beneficial-ownership data from the entity under its CDD onboarding terms, and walk the ownership chain through transparent upstream jurisdictions. Where a Swiss financial intermediary is in the relationship, that intermediary holds AML-standard beneficial-ownership records.
Does the Swiss register apply to foreign companies?
In defined circumstances, yes. The TJPG reaches certain foreign legal entities with a Swiss nexus — those with a registered Swiss branch, with effective administration (actual management) in Switzerland, or owning Swiss real estate. Trustees domiciled in or administering trusts from Switzerland are also in scope, except where they are already subject to the Anti-Money Laundering Act.
Can I rely on the Swiss register as the source of truth?
No. The Swiss Parliament explicitly rejected any presumption that the register is accurate. It is a source of information to be used as a cross-check, not relied on as definitive. Financial intermediaries and advisors who discover a discrepancy between the register and their own information are obliged to report it. This mirrors the EU AMLR's posture, which also treats registers as a cross-check rather than the primary source.
