Swiss Transparency Register: Filing is the easy part
Introduction
On October 1, 2026, Switzerland's Federal Act on the Transparency of Legal Entities (TJPG) comes into force and opens a new federal register of beneficial owners. Most of the discussion so far has focused on deadlines, thresholds, and fines. In his analysis for Silicon, DSwiss CISO Antonio Mecci argues that this focus misses the real work: under the new law, a company must be able to prove at any later point that its filing was accurate when submitted and has remained accurate since.
Key Takeaways
- The federal government estimates that more than 500,000 legal entities must identify, verify, and report their beneficial owners, with transition periods ending between December 2026 and September 2028.
- Any commercial register change after October 1, 2026 triggers a reporting obligation within one month, and intentional violations can lead to fines of up to CHF 500,000.
- The register is non-public and self-declared, so the credibility of each entry depends entirely on the supporting documents the company holds.
- Records and verification steps must be kept in Switzerland for ten years after a person's beneficial ownership ends, which makes version control as important as storage.
- Fiduciaries, smaller law and notary firms, corporate service providers, and SMEs with complex ownership structures carry the heaviest operational burden.
Switzerland's new Transparency Register works on self-declaration. Companies decide for themselves who holds at least 25 percent of capital or voting rights, submit the information through EasyGov, and a federal control office reviews entries after the fact. Because the register is closed to the public, and companies cannot even view their own entry, each filing is only as credible as the documents behind it.
The law extends that obligation well beyond the initial filing. Ownership changes must be reported within one month, records must be kept in Switzerland for ten years after a beneficial owner exits, and financial intermediaries must flag discrepancies with the register. Companies therefore need to show which documents supported which reported state, including every change along the way.
Large banks can fold these requirements into existing KYC processes. Fiduciaries, smaller law firms, corporate service providers, and SMEs with complex ownership structures face a heavier lift, often without the infrastructure to manage sensitive documents securely. Mecci connects the TJPG to DORA and NIS-2, which share the same expectation that organizations can prove compliance at any time, making controlled access, versioned records, and a documented chain of evidence a baseline requirement.
👉 Read the full article on Silicon: https://www.silicon.eu/schweizer-transparenzregister-die-meldung-ist-der-einfache-teil-19272.html
Published on: silicon.eu, September 28, 2026
Author: Antonio Mecci
Conclusion
The register opens on October 1, but the obligation continues long after the transition periods expire. Organizations that treat the date as a deadline will find themselves assembling evidence under pressure at the next inquiry or ownership change. Those that treat it as the start of a permanent documentation duty will be able to answer the question that ultimately matters to regulators and banks: whether the filing can be shown to have been correct, and to have stayed correct.
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