Switzerland Beneficial Ownership Register (LETA): UBO Data, Access & 2026 Changes
1. Switzerland's UBO Register: The State of Play in 2026
Switzerland has long been one of Europe's most significant corporate jurisdictions — home to approximately 600,000 registered legal entities, from multinational headquarters and private holding structures to family offices and collective investment vehicles. For compliance teams, KYB platforms, and financial institutions working with Swiss counterparties, understanding who ultimately controls those entities has historically been one of the hardest problems in European due diligence.
Until now, Switzerland has had no centralised UBO register. Companies were required to maintain an internal list of beneficial owners under Articles 697j et seq. of the Swiss Code of Obligations — but this was a private document, inaccessible to third parties, regulators, or the public. The result: Switzerland has been a black box for beneficial ownership data in a way that almost no other major European jurisdiction has been.
That changes with the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners — known as LETA (or TLEA in some sources). Adopted by the Swiss Parliament on 26 September 2025 and expected to enter into force in the second half of 2026, LETA establishes a central federal Transparency Register administered by the Federal Office of Justice (FOJ). It is the most significant overhaul of Swiss corporate transparency in decades.
The driver is external pressure, not internal appetite. Switzerland faces a FATF mutual evaluation in 2027. LETA is the direct response: a framework designed to close the ownership transparency gap before international reviewers arrive.
This article is part of Zavia.ai's Global Ownership Data Index, covering UBO and corporate data availability across 173 countries. Switzerland is scored as Restricted pre-LETA and Transitional from mid-2026.
2. What Is a UBO Under Swiss Law?
LETA introduces a UBO definition aligned with international AML standards and significantly clearer than the existing Code of Obligations formulation. The definition applies to all in-scope entities from the date LETA enters into force.
The 25% threshold
Under LETA, a UBO is any natural person who ultimately controls a legal entity by holding, directly or indirectly, alone or in concert with others, at least 25% of the capital or voting rights. The calculation runs through the full ownership chain. Where a natural person holds 60% of an intermediate holding company that itself owns 50% of the Swiss entity in scope, their indirect stake (30%) crosses the threshold.
Control by other means
If no individual meets the 25% threshold through capital or voting rights, LETA applies a "control by other means" test. The draft implementing ordinance (LETO) defines this as existing where a natural person can exert decisive influence over the entity — notably through the right to appoint or remove a majority of the supreme management or administrative body, through veto or approval rights over strategic decisions, or through binding contractual arrangements. The definition is non-exhaustive. Indicators of control also include formal or informal agreements among shareholders, debt instruments such as convertible or equity loans, articles of association, family links, and trust relationships.
The fallback: chair of the executive body
If a company cannot identify any natural person through ownership or control criteria, LETA designates the chair of the company's executive body as the UBO. This is a departure from the current Code of Obligations provision, which required a "negative notification" declaring that no UBO existed. Under LETA, someone is always registered.
Under the current Code of Obligations, companies keep an internal private list of beneficial owners. No central register exists. No authority has systematic access. LETA replaces this entirely — the internal list is abolished and replaced by mandatory filing with the federal Transparency Register. For the first time, Swiss authorities will have centralised, cross-checked access to beneficial ownership data for all ~600,000 in-scope entities.
Which entities must register?
| Entity Type | In Scope? | Notes |
|---|---|---|
| Corporations (AG / SA) | ✓ Yes | Core scope entity; unlisted only |
| Limited liability companies (GmbH / Sàrl) | ✓ Yes | Shareholders already publicly visible in commercial register; UBO still required |
| Cooperatives | ✓ Yes | — |
| Partnerships limited by shares (KommAG / SCA) | ✓ Yes | — |
| Investment companies (SICAV, SICAF) | ✓ Yes | — |
| Limited partnerships for collective investments | ✓ Yes | — |
| Foreign entities with a Swiss branch | ✓ Yes | Foreign entities with Swiss nexus are in scope |
| Foreign entities with effective management in Switzerland | ✓ Yes | — |
| Foreign entities owning Swiss real estate | ✓ Yes | — |
| Swiss trustees (not subject to AMLA) | ● Internal only | Must identify and retain UBO information internally; no obligation to file with Transparency Register |
| Foundations (Stiftungen) and associations (Vereine) | ✗ Exempt | Explicitly excluded from LETA's UBO identification and registration regime |
| Listed companies and their >75% subsidiaries | ✗ Exempt | Subject to separate public disclosure requirements |
| Pension institutions | ✗ Exempt | — |
3. What UBO Data Will Be Available in the Swiss Transparency Register
LETA specifies exactly what information must be collected, verified, and filed. The register will hold considerably more personal detail than the current internal lists — and critically, each entry must be actively verified, not merely declared.
| Data Field | Required to File? | Accessible to Financial Intermediaries? | Notes |
|---|---|---|---|
| Full legal name | ✓ Yes | ✓ Yes | — |
| Date of birth | ✓ Yes | ✓ Yes | — |
| Nationality | ✓ Yes | ✓ Yes | — |
| Residential address | ✓ Yes | ✓ Yes | — |
| Nature and extent of control | ✓ Yes | ✓ Yes | Must specify type of control (shares, voting rights, other means) and percentage |
| Identity verification evidence | ✓ Yes — held by entity | ● Authorities only | Verification documents retained by the filing entity; not centrally stored in the register |
| Corporate ownership chain / structure | ✗ No | ✗ No | Register records the UBO, not the intermediate chain. Chain mapping requires external sources. |
| Historical ownership records | ● Changes reported within 1 month | ● TBD | Amendments must be filed; whether historical records are queryable depends on the implementing ordinance |
| PEP / sanctions flags | ✗ No | ✗ No | Must be cross-referenced from external sources |
Unlike the current Code of Obligations regime where companies merely declared their UBOs internally, LETA requires entities to actively verify the identity and control information of each UBO. Companies must collect and retain supporting evidence — shareholder registers, articles of association, trust deeds, shareholder agreements, convertible loan documents. The Transparency Register office will cross-check disclosures against data from financial intermediaries and public authorities.
4. Who Can Access the Swiss Transparency Register?
The Swiss Transparency Register is strictly non-public. This is a deliberate policy choice — the Federal Council explicitly acknowledged the CJEU's November 2022 ruling when designing LETA, and opted for an authority-and-intermediary access model from the outset. There is no legitimate interest access route, no journalist access mechanism, and no prospect of public access under the current framework.
| Category | Access Level | Notes |
|---|---|---|
| Criminal prosecution authorities | Full — all data | Direct access; no prior conditions |
| Tax authorities (international administrative assistance) | Full — all data | — |
| MROS (Money Laundering Reporting Office Switzerland) | Full — all data | — |
| SECO (State Secretariat for Economic Affairs) | Full — all data | Embargo and sanctions enforcement |
| Federal Intelligence Service (NDB) | Full — all data | — |
| AMLA supervisory authorities and SROs | Full — all data | To extent necessary for statutory duties |
| Land registry offices (Lex Koller, real estate) | Access on request | For property transaction verification |
| Public procurement authorities | Access on request | — |
| Social security enforcement bodies | Access on request | — |
| Financial intermediaries (banks, insurers, asset managers) | Online access — AML compliance only | Access limited to what is necessary for due diligence obligations; any other use expressly prohibited |
| Advisors under AMLA (lawyers, notaries, trustees, CSPs) | Online access — AML compliance only | New "advisor" category introduced by AMLA revision; access limited to AML due diligence |
| Journalists, researchers, civil society | No access | No legitimate interest route; no public access provision |
| General public | No access | Explicitly excluded; no access route provided |
| Private plaintiffs (indirect) | Indirect only | Access may arise indirectly via criminal investigations where private plaintiffs have rights to case files |
Financial intermediaries can access the Transparency Register online — but only to fulfil their AML due diligence obligations. The legislation explicitly states that any other use is prohibited. This means Swiss UBO data from the Transparency Register cannot be used for commercial intelligence, corporate analytics, or general KYB verification beyond the strict AML context. Cross-border compliance teams and non-Swiss entities face additional barriers.
5. Current Data Availability and Cost
Until LETA enters into force — expected mid-2026 — there is no centralised UBO data for Switzerland. The current state is stark: companies hold internal private lists that no third party can access. What is available through public sources is limited to commercial register data via ZEFIX (the Federal Central Business Names Index at zefix.admin.ch), which provides entity-level data but no ownership or UBO information.
| Data Source | Cost | What You Get | UBO Data? |
|---|---|---|---|
| ZEFIX portal (zefix.admin.ch) | Free | Company name, legal form, registered office, domicile, SOGC publications, certified extracts | ✗ None |
| ZEFIX REST API | Free | Structured access to commercial register data; daily updates; no company names in bulk dataset | ✗ None |
| Cantonal commercial register extracts | CHF 17–35 per extract | Full company extract including directors, capital, statutes; GmbH shareholders publicly listed | ● GmbH shareholders only |
| Internal company UBO list (current law) | n/a — not accessible to third parties | Held by the company; not filed anywhere centrally | ✗ Not accessible |
| LETA Transparency Register (from mid-2026) | TBD — fee structure not yet published | Full UBO data for financial intermediaries and authorities | ✓ Yes — authorities and FIs only |
Switzerland's GmbH (limited liability company) structure requires shareholders to be listed in the commercial register — making them publicly visible via cantonal extract. This is the only entity type where any ownership information is publicly accessible in Switzerland today. AG (corporation) shareholders are not publicly disclosed. In practice, most significant corporate structures use AG rather than GmbH, limiting the utility of this exception for enterprise KYB workflows.
6. Penalties for Non-Compliance
LETA introduces some of the steepest beneficial ownership penalties in Europe. The headline figure — a fine of up to CHF 500,000 — applies to intentional violations. Negligence alone is not penalised under LETA, a deliberate departure from the preliminary draft that proposed sanctioning negligent breaches and received significant criticism.
Penalties under LETA are not limited to the company. The UBO themselves must notify relevant shareholders or the company directly within one month of acquiring control or becoming aware of any change. Shareholders and quota holders must notify the company within the same period. Failure to cooperate by any party is a punishable offence. For group structures with complex intermediate layers, this creates compliance obligations that must be coordinated across multiple entities and jurisdictions simultaneously.
Financial intermediaries also carry obligations. Under the AMLA revision, institutions must report discrepancies between their own KYC information and the Transparency Register within 30 days — after first notifying the client and giving them a grace period to correct the information. While failure by financial intermediaries to report discrepancies is not itself penalised under LETA, it creates significant AMLA compliance exposure.
7. Existing and Incoming Legislation
| Legislation | Year | Key Provision |
|---|---|---|
| Swiss Code of Obligations, Art. 697j et seq. | 2015 | Required companies to maintain an internal register of beneficial owners; no central filing obligation; not accessible to third parties |
| Swiss Anti-Money Laundering Act (AMLA) | 1997 / revised continuously | Required financial intermediaries to identify UBOs of clients as part of CDD; information held internally by institutions |
| FATF Mutual Evaluation of Switzerland | 2016 | Identified beneficial ownership transparency as a significant gap; Switzerland rated partially compliant on Recommendation 24 |
| Federal Council dispatch on AML framework reform | May 2024 | Proposed LETA and AMLA revision to Parliament; included central UBO register, advisor AML obligations, real estate measures |
| LETA — Federal Act on Transparency of Legal Entities (Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners) | Adopted 26 Sept 2025 | Establishes central non-public Transparency Register; ~600,000 entities in scope; CHF 500,000 penalties; FOJ as registrar |
| LETO — Implementing Ordinance (draft) | Consultation opened Oct 2025; closed Jan 2026 | Defines "control by other means", notification procedures, access conditions, transitional deadlines; final version pending |
| AMLA revision | Adopted 26 Sept 2025 alongside LETA | Extends AML obligations to "advisors" (lawyers, notaries, trustees, CSPs in high-risk activities); discrepancy reporting obligations for FIs |
| LETA entry into force | Expected H2 2026 | Date to be set by Federal Council; referendum period expired without challenge |
| FATF Mutual Evaluation (next) | Planned end 2026 / 2027 | Switzerland's forthcoming evaluation — the primary driver behind LETA's timeline |
8. Upcoming Changes: The 2026–2027 Roadmap
1. LETA entry into force (H2 2026)
The Federal Council will set the specific date. The referendum period expired without a popular vote being requested, confirming LETA will proceed. Once in force, the Transparency Register becomes operational and all filing obligations activate. The implementing ordinance (LETO) will enter into force at the same time or shortly thereafter — it is essential to the register's operation and the FATF evaluation timetable.
2. Transitional periods for existing entities
LETA provides staggered transitional deadlines for existing in-scope entities. The applicable period depends on the entity type and whether a commercial register amendment is made during the transition. For companies subject to ordinary audit, the transitional period is three months from the date LETA enters into force. For others it runs up to six months. Foreign entities in scope also have a six-month window. Newly incorporated entities must file within one month of their commercial register entry from day one.
Switzerland's transitional deadlines are short — measured in months, not years. With roughly 600,000 entities in scope, the registration workload concentrated into a 3–6 month window from the entry into force date will be substantial. Entities with complex multi-layer structures, foreign intermediate holding companies, or nominee arrangements will need to begin ownership analysis now to avoid a compliance crunch in H2 2026.
3. Implementing ordinance finalisation
The draft LETO consultation closed in January 2026. The Federal Council is now reviewing submissions and will issue the final ordinance. Key outstanding points include the precise definition of "control by other means" beyond the indicators already published, the exact fee structure for Transparency Register access, the technical platform specifications, and the procedural details for financial intermediary online access.
4. AMLA advisor obligations activate
Alongside LETA, the AMLA revision extends AML obligations to lawyers, notaries, trustees, and corporate service providers engaged in high-risk structuring activities — including setting up companies, real estate transactions, and domicile services. These advisors will need to join a recognised self-regulatory organisation (SRO), implement due diligence procedures, file suspicious activity reports with MROS, and cross-reference the Transparency Register when conducting AML diligence on clients. This is a major expansion of Switzerland's AML perimeter.
5. FATF mutual evaluation (end 2026 / 2027)
Switzerland's next FATF evaluation is the clock ticking behind all of this. The evaluation will assess whether Switzerland is now compliant with Recommendation 24 (beneficial ownership of legal persons). LETA is the primary deliverable. If LETA enters into force and the Transparency Register is operational by the time evaluators arrive, Switzerland expects to move from "partially compliant" to "compliant." A poor result would have significant implications for Switzerland's status as a global financial centre.
9. The Real Challenges of Accessing Swiss Beneficial Ownership Data
9.1 No UBO data exists for the vast majority of Swiss entities today
This is the fundamental problem. Until LETA enters into force in H2 2026, there is no centralised Swiss UBO data — for anyone. The internal lists held by companies under the Code of Obligations are private corporate documents. They cannot be requested, subpoenaed (outside of criminal proceedings), or accessed through any commercial route. For compliance teams needing to verify Swiss counterparties today, there is no direct source. Due diligence relies on voluntary disclosure, document requests, and inference from commercial register data.
9.2 Even after LETA, public access is permanently excluded
Unlike the EU, which is moving toward presumed legitimate interest access for journalists and civil society under 6AMLD, Switzerland has deliberately excluded any form of public access from LETA's framework. There is no legitimate interest access route. There is no journalist access mechanism. The draft legislation does not even provide a basis for access based on demonstration of legitimate interest. This is a permanent feature of Swiss design, not a transitional restriction pending further reform.
9.3 Financial intermediary access is AML-only — not general KYB
Even financial institutions that can access the Transparency Register are restricted to using the data solely for AML due diligence purposes. Any other use — including commercial intelligence, credit risk assessment, or general KYB verification outside the AML context — is expressly prohibited. For enterprise compliance platforms serving broad KYB use cases, this is a material constraint on how Swiss Transparency Register data can be used or redistributed.
9.4 No public shareholder data for AG structures
GmbH shareholders are publicly visible in the commercial register — but AG (corporation) shareholders are not disclosed publicly. The AG is the dominant corporate form for significant Swiss entities: multinationals, family holding companies, investment vehicles, and financial institutions. For the entity type that matters most in enterprise KYB, there is currently no ownership data available beyond what can be derived from voluntary filings and document analysis.
9.5 Complex multi-layer structures and no chain resolution
Even once LETA is operational, the Transparency Register will record the declared UBO — the natural person at the end of the chain — without mapping the intermediate corporate structure that connects them to the Swiss entity. A Swiss AG owned by a Liechtenstein Anstalt, owned by a Jersey trust, controlled by a natural person in a third country: the Transparency Register will show the natural person. It will not show the chain. Resolving that chain requires data from Liechtenstein, Jersey, and the natural person's home jurisdiction combined with the Swiss registry data — a genuinely cross-border problem.
9.6 Foreign entities with Swiss nexus face complex scoping questions
LETA's "Swiss nexus" criteria — Swiss branch, effective management in Switzerland, or ownership of Swiss real estate — are broader than they first appear. Many international group structures inadvertently meet one or more of these criteria. A holding company managing Swiss assets from a Geneva family office, a Luxembourg SARL with a Swiss branch for administrative purposes, a Cayman fund owning a Swiss chalet: all potentially in scope. The ordinance will clarify the precise boundaries, but until then, the scoping analysis for complex international structures is genuinely uncertain.
9.7 Nominee arrangements carry new complexity
LETA introduces explicit obligations around nominee relationships that did not previously exist. Nominee directors, shareholders, and partners must now disclose their acting as nominee to the relevant company, along with the identity of their principal. Switzerland's financial centre has historically accommodated significant nominee activity. The new regime requires those structures to be unwound from an information perspective — even if the nominee arrangement itself remains legally valid.
10. How Zavia.ai and Global Database Resolve Swiss Beneficial Ownership Access
Switzerland's LETA Transparency Register will be operational from H2 2026 — but non-public, access-restricted, and usable only for AML compliance purposes by authorised institutions. For cross-border compliance teams, KYB platforms, and financial institutions needing to verify Swiss counterparties today — or needing chain-level ownership data beyond what any single register provides — the challenge is fundamentally different.
For Swiss entities embedded in multi-layer international group structures, the most effective path to UBO identification is not the Swiss register alone — it is tracing the ownership chain upward to the ultimate parent. Global Database provides deep corporate linkage coverage for Swiss entities, mapping subsidiary-to-parent relationships across jurisdictions. By identifying the ultimate parent company first, compliance teams can then direct their UBO search to the jurisdiction where ownership is most transparent — significantly reducing reliance on the Swiss register's access restrictions.
This matters because Switzerland is disproportionately a subsidiary jurisdiction. Many Swiss entities are not standalone companies — they are held by foreign parents registered in Germany, the UK, the US, or Luxembourg. In those jurisdictions, beneficial ownership data may already be accessible. Corporate linkage data from Global Database identifies the ultimate parent, the group structure, and the jurisdiction where beneficial ownership information is most available — enabling a chain-level UBO resolution strategy that does not depend on the Swiss Transparency Register at all.
🇨🇭 Swiss Corporate Ownership Data via the Zavia.ai API
One API endpoint. Real-time access to Swiss company data, corporate linkage, group structure mapping, and cross-border UBO resolution — sourced directly from ZEFIX and the cantonal commercial registers.
- Real-time Swiss company queries by UID / ZEFIX number
- Corporate linkage — subsidiary, parent, ultimate parent
- GmbH shareholder data from cantonal extracts
- Cross-border ownership chain resolution (173 countries)
- Bulk data delivery — licensed file exports at scale
- Sanctions overlay and KYB verification workflow
- Director history and company document retrieval
- Full reseller and redistribution rights available
Why corporate linkage changes the Swiss UBO problem
Consider a Swiss AG that is a wholly owned subsidiary of a German GmbH, which is itself majority-owned by a UK-registered holding company. The Swiss Transparency Register — when operational — will tell you the natural person who ultimately controls the chain. But it tells you nothing about the intermediate structure. Global Database's corporate linkage data maps the full chain: Swiss AG → German GmbH → UK holding → natural person. From the UK end, beneficial ownership is available via Companies House. The Swiss register becomes one node in a cross-border ownership graph — not the single source of truth.
What Zavia.ai provides today — before LETA
While the Swiss Transparency Register does not yet exist, Zavia.ai provides structured access to Swiss commercial register data via ZEFIX and cantonal registers — including company profiles, directors, GmbH shareholders, historical filings, and group structure linkage — through a single internationally accessible API. No Swiss entity registration, no cantonal register account management, no per-extract manual ordering.
