Transparency register: reporting obligation and deadlines
As at: · fastview ag, Suhr
Professionally responsible: Marco Zanetti and Reto Ackermann, fiduciaries and auditors, fastview ag
Since 1 October 2026, companies limited by shares, GmbHs and cooperatives report their beneficial owners to the federal transparency register. This page summarises who reports, what is reported, which deadline applies to which company and what the reporting channel looks like. At the end you will find how nunia prepares the report from the share register.
In brief
- Legal basis: Transparency Act TJPG (SR 955.3) and Ordinance TJPV (SR 955.31), both in force since 1 October 2026.
- Every natural person who holds at least 25 % of the capital or votes or otherwise controls the company is reported; if there is none, the most senior member of the managing body.
- First deadlines: AGs with an ordinary audit by 31.12.2026, other AGs by 28.02.2027, GmbHs and cooperatives by 31.03.2027. A change in the commercial register shortens the deadline to one month.
- Reporting is free of charge via EasyGov with AGOV login, by the company or an authorised person.
What has applied since 1 October 2026
The Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) and the associated Ordinance (TJPV) entered into force on 1 October 2026. The transparency register is kept by the Federal Office of Justice. It is not public: access is granted to authorities as well as to financial intermediaries and advisers under the Anti-Money Laundering Act for their due diligence obligations (Art. 25–27 TJPG).
The TJPG replaces the previous reporting obligation of shareholders under Art. 697j–697m CO; these articles have been repealed. Reports under the old law count as reports under Art. 13 TJPG insofar as the persons are also beneficial owners under the new law. The previous register is not continued but is retained for ten years (Art. 49–50 TJPG).
Who must report
| Legal form | Reporting obligation | Basis |
|---|---|---|
| Company limited by shares, partnership limited by shares, GmbH, cooperative | yes | Art. 2 of the TJPG |
| SICAV, SICAF, limited partnership for collective investment (KmGK) | yes | Art. 2 of the TJPG |
| Legal entity under foreign law with a branch, effective administration or real estate in Switzerland | yes | Art. 2 of the TJPG |
| Association, foundation | no | Art. 2 of the TJPG |
| Sole proprietorship, general and limited partnership | no, not a legal entity | Art. 2 of the TJPG |
Exempt are listed companies and their subsidiaries in which they hold more than 75 %, pension institutions and companies at least 75 % owned by public bodies (Art. 3 TJPG). For the typical family AG or single-person GmbH the obligation applies without restriction.
Who counts as a beneficial owner
The beneficial owner is the natural person who ultimately controls the company (Art. 4 TJPG):
- through a holding: directly or indirectly, alone or in concert, at least 25 % of the capital or votes. Indirectly means, under the Ordinance: more than 50 % of an intermediate entity that itself holds at least 25 %.
- in another way: for example the right to appoint or dismiss the majority of the board of directors, a veto right on strategy, budget or financing, or the ability to bring about profit distributions, for example under a shareholders’ agreement. Both are specified in Art. 1–4 TJPV.
- subsidiarily: if there is no such person, the most senior member of the managing body is reported, i.e. the chair of the management if there is a separate management, otherwise the chair of the board of directors; the function is reported as well (Art. 4 para. 2 TJPG, Art. 20 para. 3 TJPV).
What is reported
For each beneficial owner, the company reports to the register (Art. 9 TJPG, Art. 10–13 TJPV):
- surname and first names, date of birth, nationalities,
- municipality, postcode and country of residence, not the exact address,
- type of control: alone or in concert, direct or indirect, through a holding or in another way,
- extent in one of three bands: 25–50 %, over 50–75 % or over 75 %.
Internally, the company keeps a register with these details, the address and the supporting documents, accessible in Switzerland at all times and retained for ten years beyond the end of the status (Art. 7–8 TJPG). For identification it establishes whether the person has an OASI number; without an OASI number, a copy of the passport, identity card or residence permit is part of the supporting documents (Art. 10 TJPV). The shareholders for their part are obliged to report the beneficial owner to the company within one month (Art. 13 TJPG).
Deadlines for the first report
Companies that already existed on 1 October 2026 report within the transitional periods of Art. 51 TJPG. What matters is the legal form and whether the company must have its financial statements audited in an ordinary audit.
| Case | Deadline | By | Basis |
|---|---|---|---|
| First change to the commercial register entry after 1 October 2026 | one month after the change, takes precedence over the longer periods | ongoing | Art. 51 para. 1 |
| Company limited by shares with an ordinary audit | three months | 31.12.2026 | Art. 51 para. 3 let. a |
| Other company with an ordinary audit | four months | 31.01.2027 | Art. 51 para. 3 let. b |
| Company limited by shares without an ordinary audit | five months | 28.02.2027 | Art. 51 para. 3 let. c |
| Other companies, such as GmbH and cooperative | six months | 31.03.2027 | Art. 51 para. 3 let. d |
| All beneficial owners are entered in the commercial register as members or governing body | two years | 30.09.2028 | Art. 51 para. 2 |
| New incorporation | one month after entry in the commercial register | ongoing | Art. 9 para. 4 |
Changes are reported by the company within one month of becoming aware of them (Art. 10 TJPG). A changed holding only needs to be reported if it crosses the threshold of 25, 50 or 75 % upwards or downwards. Company name, legal form, registered office and postcode are taken over by the register itself from the commercial register; a change of residence of a reported person remains reportable (Art. 39 TJPV). The registry authority checks whether a report was made no earlier than six months after entry into force and issues reminders (Art. 52 para. 2 TJPG).
Responsibility and fines
The most senior member of the managing body is responsible for the report. It may delegate the task to persons within the company or to third parties, for example the fiduciary firm; responsibility remains with the body (Art. 12 TJPG). Anyone who intentionally breaches the reporting obligations or provides false information is punished with a fine of up to CHF 500 000 (Art. 43 TJPG); negligent conduct is not punishable. The supervisory office may demand information, add a note in the register and, in the case of repeated breaches, suspend the participation and property rights of the shareholder concerned (Art. 34 and 38 TJPG).
Reporting channel: EasyGov with AGOV
- Portal: reporting is done electronically via EasyGov.swiss, the federal platform for businesses (Art. 22 TJPG). Login is via an AGOV account of a natural person; the company is linked via its UID.
- Power of attorney: at least one person is authorised in writing. EasyGov sends the power of attorney form by post to the company’s registered office; it is signed in accordance with the signing authority in the commercial register (Art. 26–31 TJPV). In this way the fiduciary can also report on behalf of the client.
- Costs: registration, change and deletion are free of charge; an extract costs CHF 40 (Art. 68 TJPV).
- Simplified procedure: for a GmbH whose members are natural persons and at the same time the beneficial owners, and for the single-person AG whose sole shareholder is registered as the sole member of the board of directors (Art. 35–37 TJPV).
- Via the commercial register office: anyone filing an entry in the commercial register anyway can submit the report there with a separate form (Art. 11 TJPG, Art. 32–34 TJPV).
- No interface: the Ordinance provides for a technical interface for reporting from software only as a possibility (Art. 26 para. 2 TJPV); it is not offered today. AGOV is a login, not a data interface. Submission is therefore done manually in the portal.
How nunia prepares the report
In nunia the “Transparency register” card is located in the client’s share register. It links the obligation with the data that is kept anyway:
- Propose persons: nunia proposes from the share register all natural persons with 25 % or more of the capital or votes. If a legal entity holds 25 % or more, nunia points to the chain of control; if nobody holds 25 %, nunia proposes the most senior member of the managing body from the governing bodies.
- Complete the details: date of birth, nationalities, municipality of residence, postcode and country, type and extent of control as well as OASI number available yes or no, otherwise the copy of the identity document as supporting document.
- Deadline per company: nunia calculates the reporting deadline under Art. 51 TJPG from the legal form, type of audit and the commercial register dates and shows the rule applied with the article. If the type of audit is not known, nunia assumes the earlier deadline.
- Reporting sheet (PDF): one sheet per company with checklist and the details per person in the order of the EasyGov form, as a template for the report or as an enclosure for the client. “Open EasyGov” leads directly to the portal.
- Record the report: after submission you record the date, channel (EasyGov or commercial register office) and the confirmation as evidence.
- Follow-up report: if a change in the share register takes a holding above or below 25, 50 or 75 %, nunia sets the reporting status to “Change open” and creates a task with the one-month deadline.
What nunia takes care of
- Propose reportable persons from the share register and governing bodies
- Keep the details under TJPG and TJPV complete
- Calculate the reporting deadline per company under Art. 51 TJPG
- Generate the reporting sheet in the order of the EasyGov form
- Record reporting status and evidence
- Remind of the follow-up report when thresholds are crossed
What you decide
- whether a person controls the client in another way
- identification and verification of the details with supporting documents
- whether you report with a power of attorney or the client reports themselves
- submitting the report in the EasyGov portal
Sources
- Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) of 26.09.2025, SR 955.3, BBl 2025 2900
- Ordinance on the Transparency of Legal Entities (TJPV) of 12.06.2026, SR 955.31, as at 01.10.2026
- Federal Office of Justice, Swiss Transparency Register; EasyGov.swiss, Report to the transparency register
Read on and watch
Frequently asked questions
Does a small family AG also have to report to the transparency register?
Yes. Every company limited by shares, GmbH and cooperative is subject to it, regardless of size and number of shareholders (Art. 2 of the TJPG). Exempt are only listed companies and their subsidiaries, pension institutions and companies at least 75 % owned by public bodies.
By when must an existing company report?
AGs with an ordinary audit by 31.12.2026, other companies with an ordinary audit by 31.01.2027, AGs without an ordinary audit by 28.02.2027, other companies such as GmbH and cooperative by 31.03.2027. If the commercial register entry is changed before then, one month from the change applies. If all beneficial owners are entered in the commercial register as members or governing body, 30.09.2028 applies (Art. 51 TJPG).
Do associations and foundations have to report?
No. Associations and foundations are not subject to the TJPG. Sole proprietorships and partnerships are not legal entities and do not report either.
May the fiduciary report on behalf of the client?
Yes, with a written power of attorney from the company. EasyGov sends the power of attorney form to the registered office; after signing, the authorised person reports with their AGOV account. Responsibility remains with the most senior member of the managing body (Art. 12 TJPG).
What does the report cost?
Nothing. Registration, change and deletion are free of charge; an extract costs CHF 40 (Art. 68 TJPV). Intentional breaches of the reporting obligation are punished with a fine of up to CHF 500 000 (Art. 43 TJPG).
When must a change be reported?
Within one month of becoming aware of it (Art. 10 TJPG). A changed holding only needs to be reported if it crosses 25, 50 or 75 % upwards or downwards; a change of residence of a reported person must always be reported. Company name, registered office and legal form are taken over by the register from the commercial register.
Can nunia report directly to the transparency register?
No, because the Confederation does not offer an interface for reporting from software. nunia prepares the report completely: persons, details, deadline and a reporting sheet in the order of the EasyGov form. Submission is done in the EasyGov portal.
Try nunia
The system tour shows the “Transparency register” card in the share register with sample clients, no registration required. For questions about your firm, book an online demo.