The beneficial ownership register: what changes on 1 October 2026
Switzerland has been an outlier among major financial centres in having no central register of beneficial owners. From 1 October that ends, and more than half a million Swiss entities acquire a reporting obligation most of their boards have not yet read.
On 26 September 2025 Parliament adopted the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, together with a revision of the Anti-Money Laundering Act. The referendum period passed without challenge. On 12 June 2026 the Federal Council published the implementing ordinance and fixed the date: both take effect on 1 October 2026.
The timing is not accidental. Switzerland faces a Financial Action Task Force country evaluation in 2027–2028, and the register is the answer to the gap the last one identified. What follows is the practical shape of the obligation, as it stands after the ordinance.
What the register is
A centralised federal register of beneficial owners, operated by the Federal Office of Justice and filed through the EasyGov portal. It is not public. Access is limited to competent Swiss authorities and, for know-your-customer purposes, to financial intermediaries and advisers subject to anti-money-laundering supervision. This is the point most often misread: the obligation is real, the exposure is not.
Who has to report
In principle every Swiss incorporated entity: the SA/AG, the Sàrl/GmbH, cooperatives, SICAV and SICAF. Foreign entities are caught where they have a Swiss nexus — a registered branch, an effective place of management in Switzerland, or Swiss real estate — and certain trustees fall in as well.
Outside the scope: listed entities, subsidiaries more than 75% held by one or more listed companies, entities at least 75% held by public authorities, pension funds, Swiss associations, Swiss foundations and Swiss sole proprietorships. The two thresholds are not the same one: Article 3 of the Act says more than 75% for subsidiaries of listed companies and at least 75% for public ownership, so a company held exactly 75% by a listed parent is inside the scope and not outside it.
A beneficial owner is the natural person who ultimately holds, directly or indirectly, alone or in concert, at least 25% of capital or votes — or who controls the entity by other means.
Those last five words are where the work is. Shareholders' agreements, usufruct arrangements, options, family pacts and financing covenants can all confer control without appearing on a cap table. The law asks the company to reach a conclusion about arrangements it is sometimes not even a party to. Where no beneficial owner can be identified despite genuine diligence, the entity reports its most senior director instead — a fallback, not a shortcut.
By when
Transitional periods run from 1 October 2026 and depend on legal form and circumstances. Broadly:
- ·Three to six months for existing entities, depending on audit category — so first filings fall due between January and April 2027.
- ·Two years where the beneficial owners are all already entered in the commercial register as partners or members of a governing body.
- ·1 May 2027 for foreign-law entities, which must also appoint a representative or a registered address in Switzerland.
- ·One month from the first change to the commercial register entry occurring on or after 1 October 2026, which cuts the transitional period short — and one month from every change after that.
What we would do now
Nothing here needs a project. It needs someone to sit down with the corporate file before the autumn, and for most of our clients that takes an afternoon.
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1
Map the entities.
Which companies in the group are in scope, and which of the exemptions actually applies — the 75% test in particular is often assumed rather than checked.
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2
Read the agreements, not just the register.
Control by other means is the part that produces surprises, and it is usually documented somewhere other than the share ledger.
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3
Fix the evidence.
The obligation is to identify, verify and document — a conclusion with nothing behind it will not survive a later question.
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4
Give the update duty an owner.
The one-month rule turns this into a standing process, not a single filing. Someone has to hold the calendar.
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5
Advisers should also check themselves.
The AMLA revision touches who falls within scope, and whether membership of a recognised self-regulatory organisation becomes necessary.
Groups with layered or foreign holding structures should start earlier than they think they need to. Establishing who controls an entity is quick when the answer is one person and one share register. It is not quick when the answer runs through three jurisdictions and a shareholders' agreement signed in 2011.
Sources
Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners, adopted by Parliament on 26 September 2025; implementing ordinance published by the Federal Council on 12 June 2026, with entry into force set for 1 October 2026; accompanying revision of the Anti-Money Laundering Act.
This article is general information current at the date of publication. It is not advice in an individual case, and the treatment of any particular structure depends on its facts.
Not sure whether your structure is in scope?
Send us the shareholding chart. We will tell you which entities report, by when, and where we think the control question is not as settled as it looks.