Swiss Transparency Register
Impacts for affected entities and financial intermediaries
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Impacts for affected entities and financial intermediaries
The Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LETA), its accompanying implementing regulations – in particular the Ordinance on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPV) – and the amended Anti-Money Laundering Act (AMLA) will come into force on 1 October 2026.
Key points at a glance
What does that mean for entities affected by the LETA?
Obligation to inform: In future, entities affected by the LETA1 will be obliged to identify their beneficial owners, to review the beneficial owners' corresponding details with appropriate due diligence, to disclose them to the Transparency Register, and to keep them updated.
A beneficial owner is considered to be a natural person who ultimately controls an entity because, either directly or indirectly, and either solely or jointly with third parties, he or she holds at least 25% of the share capital or voting rights, or exercises control over the entity through other means [fedlex.admin.ch]. In relation to such persons, there will now be an obligation to acquire, review and report, in particular, first and last names, date of birth, nationality, town/city, zip code and country of residence, as well as information on the nature, extent and structure of the control exercised. Information must also be provided on whether a beneficial owner has an AHV number, and where this is not the case, a copy of the person's ID must be provided. For the entity with an obligation to inform, the particular details to be recorded and reported are the name of the company, its legal form, its registered address and, if available, its enterprise identification number (UID). Further information is available on the official Transparency Register website under "How-can-a-company-register".
For existing entities with an obligation to inform, the transition periods begin when the LETA comes into force on 1 October 2026. The introduction will be staggered and can take up to two years depending on the category applied; the exact deadline is determined according to the statutory and regulatory requirements.
For specific constellations, a simplified reporting procedure is planned, in particular for:
What does this mean for Swiss financial intermediaries?
Checking the register and reporting discrepancies: Financial intermediaries as defined by the AMLA, including wealth managers, need to register as such with the Transparency Register (e.g. via EasyGov) and are then granted access in order to fulfill their statutory due diligence obligations [fedlex.admin.ch].
As part of the KYC or AMLA due diligence and reporting processes, financial intermediaries will in future be able to compare the register data with their own client information (see here also How-can-I-view-the-register). In the event that they identify substantial discrepancies, financial intermediaries are responsible for clarifying these with the client. They must also check whether any discrepancies, which have not been clarified, must then be reported within a specified time period according to the requirements of the Transparency Register.
In general, it may be useful for affected entities to review their ownership and control structures in advance, to identify the individuals who are beneficial owners, and to gather the relevant information in order to ensure compliance with the statutory reporting deadlines.
It may also be worthwhile for wealth managers to review their existing KYC or AMLA processes with regard to the new obligations to identify beneficial owners, for checking the register and reporting discrepancies, and to adapt such processes as required.
This information is intended exclusively for general guidance on the Swiss Transparency Register and the regulatory developments associated with it. It does not represent legal, regulatory, tax or other advice, nor is it a substitute for an individual case review. Specific obligations can vary according to legal form, activity, client situation and control structure. Addressees should seek qualified advice if they have any questions regarding legal or regulatory matters.
Additional information:
1Note: Certain entities are excluded from the scope of the LETA. These include, in particular, legal persons whose equity securities are quoted entirely or in part on a stock exchange, as well as subsidiaries of which more than 75% is held either directly or indirectly by one or several such listed companies. For entities that are held only partially by a listed entity, there may be certain simplifications.