Swiss Transparency Register: reporting the beneficial owners
From 1 October 2026, AGs, GmbHs and cooperatives must report to the Swiss Transparency Register which natural persons control them. As your fiduciary, Triana identifies your beneficial owners, verifies the documents and files the report via EasyGov, for a single company as well as for a multi-tier holding. You sign a power of attorney and we take care of the rest: initial report at a fixed price, confirmation from the register for your records, monitoring of follow-up reports. Check in two minutes whether and by when your company has to report.
Reply within 24 hours on working days | Fixed-price quote within 48 hours | Confirmation from the register for your records
MemberThe key facts
Who reports
AGs, partnerships limited by shares, GmbHs, cooperatives, SICAVs and SICAFs, as well as foreign legal entities with a branch, effective management or real estate in Switzerland. No reporting duty for associations, foundations, sole proprietorships, partnerships and listed companies (Art. 2 and 3 LETA).
By when
New companies within one month of the commercial register entry. Existing companies by 30 September 2028 if all beneficial owners are in the commercial register, otherwise within three to six months, i.e. between the end of December 2026 and the end of March 2027. The first change to the commercial register after 1 October 2026 shortens any deadline to one month (Art. 9 and 51 LETA).
Who is reported
Every natural person holding at least 25 percent of the capital or votes, directly or indirectly, or exercising control in another way. If there is no such person, the most senior member of the management body is reported (Art. 4 LETA).
Costs and penalties
Entry, amendment and confirmation are free of charge; a register extract costs CHF 40, reminders from the authority CHF 100 to 150 per hour. Anyone who intentionally breaches the reporting duty risks a fine of up to CHF 500'000 (Art. 43 LETA).
Delegation
The most senior member of the management body is responsible. They may delegate the report to a third party, for example a fiduciary firm (Art. 12 para. 2 LETA). That is exactly what we take on.
Check your reporting duty and deadline in two minutes
Six to eight questions on legal form, ownership structure and audit status. You immediately get your reporting deadline with date and article of law, the right reporting procedure and the list of documents. Free of charge, no sign-up, your answers never leave the browser.
What is the legal form of your company?
The legal form entered in the commercial register is decisive.
Question 1 of up to 8
Guidance based on LETA and its Ordinance, as of 14 September 2026. The wording of the Act and the practice of the register authority are authoritative. In our reading, deadlines in months end at the end of the month; reporting earlier keeps you on the safe side. Your answers stay in the browser and are not transmitted.
Who has to report to the Transparency Register?
LETA covers the vast majority of Swiss corporations. What counts is the legal form, not the size: the one-person GmbH reports just like the industrial holding.
| Situation | Must report? | What is reported |
|---|---|---|
| SME AG, all shareholders natural persons | Yes | Every person with at least 25% of the shares or votes. Shareholders outside the board of directors are not entered in the commercial register, so the short transitional deadline applies. |
| GmbH whose partners are natural persons | Yes | Partners with at least 25% of the share capital. They are entered in the commercial register: long transitional deadline and simplified procedure possible (Art. 35 of the Ordinance). |
| Holding AG with an operating GmbH | Yes, both | The holding reports its shareholders. The GmbH reports the persons behind the holding: anyone holding more than 50% of the holding, which in turn holds at least 25% of the GmbH (Art. 2 of the Ordinance). |
| Cooperative | Yes | Persons with at least 25% of the votes or control in another way; otherwise the most senior member of the management body, i.e. the chair of management or of the board (Art. 4 para. 2 LETA, Art. 20 of the Ordinance). |
| Widely held AG, no one reaches 25% | Yes | Subsidiarily the most senior member of the management body: the chair of management or, without separate management, the chair of the board of directors. |
| Subsidiary more than 75% held by a listed company | No | Exemption under Art. 3 let. a LETA. If the holding falls to 75% or below, the reporting duty arises. |
| Association, foundation, sole proprietorship, general partnership | No | Not covered by Art. 2 LETA. If a foundation or association controls an AG or GmbH, however, that company reports under Art. 7 and 8 of the Ordinance. |
| German GmbH with a branch in Switzerland | Yes | Art. 2 para. 1 let. b LETA. The company also needs a representative or an address for service in Switzerland (Art. 17 LETA). |
| Foreign company with real estate in Switzerland | Yes | On an acquisition under Art. 4 of the Lex Koller (BewG), the entry in the Transparency Register must be proven to the land registry (Art. 40 LETA). |
Who counts as a beneficial owner?
A beneficial owner is always a human being, never a company. The Act names three ways of exercising control (Art. 4 LETA, Art. 1 to 3 of the Ordinance). First, a direct holding of at least 25 percent of the capital or votes. Second, an indirect holding through one or more intermediate companies: more than 50 percent of the intermediate company, which in turn holds at least 25 percent. Third, control in another way, such as the right to appoint the majority of the board of directors, a veto over strategy and budget or the power to bring about profit distributions, whether through shareholder agreements, options, convertible bonds or fiduciary arrangements. Anyone who coordinates their votes with others is counted with the joint holding.
For the report, the register needs each person's name, date of birth, nationalities, municipality and country of residence as well as the type and extent of control in three bands: 25 to 50 percent, over 50 to 75 percent, over 75 percent (Art. 9 LETA, Art. 13 of the Ordinance). The company must verify the details with the care required by the circumstances, document them and keep them for ten years (Art. 7 and 8 LETA). We take on this verification step, because it later decides whether an inspection by the authority goes through without follow-up questions.
Who has to report to the Transparency Register, and by when
The transitional deadlines run from 1 October 2026 (Art. 51 LETA). They do not depend on size but on two questions: are all beneficial owners entered in the commercial register, and is the company subject to an ordinary audit?
| Company | Deadline | At the latest | Legal basis |
|---|---|---|---|
| Newly formed or converted from 1 October 2026 | 1 month after the commercial register entry | ongoing | Art. 9 para. 4 LETA |
| Existing company, all beneficial owners in the commercial register as partners or officers (typically: GmbH with natural persons; AG whose shareholders all sit on the board of directors) | 2 years | 30 September 2028 | Art. 51 para. 2 LETA |
| AG with an ordinary audit | 3 months | End of December 2026 | Art. 51 para. 3 let. a LETA |
| Other company with an ordinary audit | 4 months | End of January 2027 | Art. 51 para. 3 let. b LETA |
| AG without an ordinary audit (most SME AGs with shareholders outside the board of directors) | 5 months | End of February 2027 | Art. 51 para. 3 let. c LETA |
| Other companies and legal entities without an ordinary audit (GmbH with companies as partners, cooperatives, SICAV) | 6 months | End of March 2027 | Art. 51 para. 3 let. d LETA |
| Legal entities under foreign law | 6 months | End of March 2027 | Art. 53 LETA |
| Any later change (new person, crossing a band upwards or downwards, departure) | 1 month after becoming aware | ongoing | Art. 10 LETA, Art. 39 of the Ordinance |
The one-month rule that shortens two years to one month
Art. 51 para. 1 LETA: existing companies must report no later than one month after the first change to their commercial register entry made after 1 October 2026. A new board member, a move of the registered office, an amendment to the articles of association or a new signing authority triggers this deadline, regardless of whether the company would otherwise have two years. The commercial register office points out the reporting duty at the first change and informs the register (Art. 52 LETA). If you are planning a change, report beforehand.
In short: the AG is in a hurry, the GmbH usually is not. In a GmbH, the partners are entered in the commercial register, so the two-year deadline normally applies. In an AG, the shareholders are not publicly listed anywhere; as soon as a beneficial owner is not also a board member, the five-month deadline applies, or three months with an ordinary audit. Anyone who changes something in the commercial register after 1 October 2026 is told about the reporting duty by the commercial register office; no earlier than six months after entry into force, the register authority checks whether these companies have reported and sends out requests subject to a fee (Art. 52 LETA). Independently of this, the control office of the Federal Department of Finance checks the accuracy and completeness of the entries (Art. 35 LETA). Whether your company is subject to an ordinary or a limited audit is explained in our short answer Audit: when is it mandatory? (in German).
What we take care of for you
Three services, one result: a correct, documented and timely entry in the Transparency Register, with confirmation for your records. You can also commission the initial report if your accounting is kept elsewhere.
Initial report at a fixed price
CHF 250 for one beneficial owner, CHF 100 for each additional person
For AGs, GmbHs and cooperatives whose shares are held directly by natural persons.
- Review of legal form, exemptions, deadline and reporting procedure
- Identification of all beneficial owners under Art. 4 LETA
- Collecting and verifying the documents: AHV number, ID copies, share register
- Power of attorney and access to EasyGov, entry and filing of the report, simplified procedure where permitted
- Confirmation from the register and documentation under Art. 8 LETA for your records
Initial report with structure analysis
Fixed-price quote within 48 hours
For holdings, multi-tier shareholdings, fiduciary arrangements, shareholder agreements and owners abroad.
- Chain of control down to the natural person, level by level with percentages
- Review of the 25, 50 and 75 percent thresholds for each company in the group
- Documentation under Art. 15 of the Ordinance, including fiduciary and control agreements
- One report per company in the group that must report, coordinated and on time
- Specific legal questions remain with your in-house or external specialists; we provide them with the prepared structure
For existing Triana clients
CHF 200 for one beneficial owner, CHF 75 for each additional person
If we keep your accounts or prepare your annual financial statements, we already have the share register, the register of beneficial owners and the audit status.
- Initial report without collecting the data again; you only confirm
- Ongoing maintenance on request: monitoring of the thresholds with every change in ownership
- Change report within one month, reminder before every change to the commercial register
- Annual review of the entry together with the annual financial statements
How the Transparency Register report works with Triana
The documents we need from you
The more complete the documents, the faster the report. We obtain anything missing together with you.
About the company
- Current commercial register extract or the company's UID
- Share register with the percentages held
- Register of beneficial owners under Art. 697l or 790a CO, if kept
- Articles of association, shareholder agreements, option or conversion rights, fiduciary agreements
- For groups: organisation chart of the chain of shareholdings with percentages and commercial register extracts of the intermediate companies
- Latest audit report or details of the audit status (ordinary, limited, opting-out)
About each beneficial owner
- Surname and first names, date of birth, all nationalities
- Municipality of residence, postcode and country of residence
- AHV number; without an AHV number, a copy of the passport, identity card or foreign national's permit (Art. 10 of the Ordinance)
- Type of control: alone or jointly, directly or indirectly, through a shareholding or in another way
- Size of the holding: 25 to 50 percent, over 50 to 75 percent or over 75 percent
- Who in your company should receive the confirmation from the register
Data protection: the register stores the municipality and country of residence, not the street address. The AHV number is used for matching with the Confederation's central person database and does not appear in any extract (Art. 46 of the Ordinance). ID copies serve to verify identity and are not published. We process and store your documents in Switzerland in accordance with the Federal Act on Data Protection (FADP) and pass them on exclusively to the Transparency Register.
Why file the report through a fiduciary firm?
Delegation is provided for by law, responsibility remains
Art. 12 para. 2 LETA allows the board of directors or management to delegate the report to third parties; the Federal Office of Justice expressly names a fiduciary company as an example. Your management body remains responsible. That is why, as your fiduciary, we document every review so that it stands up to an inspection by the control office of the Federal Department of Finance, and you sign nothing you cannot follow.
We know the structure before the report begins
Based in Zug, we look after more than 150 clients throughout Switzerland, including holdings, family businesses and group subsidiaries. The share register, the register of beneficial owners and the audit status are part of day-to-day business for fiduciary clients. These are exactly the three things that determine the deadline and procedure in the Transparency Register.
One contact person for the years to come
The initial report is only the beginning. Every sale of shares, every inheritance, every new investor can shift a threshold of 25, 50 or 75 percent, and every change to the commercial register starts the one-month deadline. If you keep your accounting and annual financial statements with us, these events land on our desk anyway. We report them on time.