Swiss AML revision and the new transparency register: what applies now

Short answer: Since 1 October 2026 the revised Swiss Anti-Money Laundering Act (Geldwäschereigesetz, GwG) and the Transparency Act (TJPG) have been in force, and the federal transparency register is operating. Companies limited by shares (AG), limited liability companies (GmbH), cooperatives and other companies must report their beneficial owners – natural persons holding at least 25 % of capital or votes, or controlling the company by other means (Articles 4 and 9 TJPG). Depending on legal form and audit requirement, existing companies must report by 31 December 2026 to 31 March 2027 at the latest (Article 51 TJPG). Advisers involved in certain transactions are now also subject to the GwG and must apply to join a self-regulatory organisation (SRO) by 1 December 2026.

This article is for board members, managing directors, compliance teams in banks, and law firms and fiduciaries in Switzerland. It explains what the Swiss transparency register requires, who is newly subject to the GwG, which deadlines apply and how much capacity implementation takes.

What changes: the transparency register and new obligations

The revision introduces two changes: a central register of beneficial owners and the inclusion of certain advisory activities under the GwG. Parliament adopted the TJPG together with the GwG revision on 26 September 2025; the Federal Council brought both into force, together with the ordinances, on 1 October 2026. Provisions on official notaries are excluded for now.

Company obligations under the TJPG

• Identify and verify: the company identifies its beneficial owners and verifies their identity with due care, requesting supporting documents from shareholders and third parties (Article 7 TJPG).
• Management as fallback: if nobody meets the 25 % threshold or controls the company by other means, the most senior member of the governing body is treated as the beneficial owner (Article 4(2) TJPG).
• Document: the information must be kept up to date and accessible in Switzerland at all times; records must be retained for ten years after a person ceases to be a beneficial owner (Article 8 TJPG).
• Report: new companies report within one month of entry in the commercial register, and changes within one month of becoming aware of them (Article 9(4) and Article 10 TJPG).
• Responsibility: the report is the duty of the most senior member of the governing body, who may delegate the task but remains responsible (Article 12 TJPG).

Shareholders with control must report the beneficial owner to the company within one month (Article 13 TJPG). If all beneficial owners are already entered in the commercial register as partners or officers, the report can also be filed through the commercial register office (Article 11 TJPG).

Who can access the register

The register is kept by the Federal Office of Justice (Article 20 TJPG). Besides authorities, financial intermediaries and advisers may access it online insofar as they need the data for their due diligence under the GwG (Articles 25–27 TJPG). The company itself can request a confirmation or an extract (Article 28 TJPG). The legal text is published in the Federal Gazette (BBl 2025 2900).

Who is affected: companies, advisers, financial intermediaries

Three groups are affected, with different duties: companies report their beneficial owners, advisers now carry GwG due diligence obligations, and financial intermediaries reconcile their KYC data with the register.

Companies

The TJPG covers companies limited by shares, partnerships limited by shares, limited liability companies, cooperatives, SICAVs, SICAFs and limited partnerships for collective investment. It also covers foreign legal entities with a registered branch, effective management or real estate in Switzerland (Article 2 TJPG). Listed companies and subsidiaries more than 75 % owned by them, pension funds and legal entities at least 75 % owned by public bodies are exempt (Article 3 TJPG).

Advisers

The GwG now covers anyone who professionally assists third parties with financial transactions relating to:

• the purchase and sale of real estate;
• the formation of non-operating legal entities in Switzerland or of legal entities abroad;
• the management and administration of non-operating legal entities and their contributions and distributions;
• the purchase and sale of legal entities through a non-operating legal entity.

Anyone who professionally provides a domicile or registered office for more than six months is also covered (Article 2(3bis) and (3ter) GwG, GwG on Fedlex). Exemptions apply, among others, to lawyers and notaries for activities related to court, criminal, administrative or arbitration proceedings, to transactions under family, matrimonial property and inheritance law, to transfers of real estate or businesses below CHF 5 million paid entirely through financial intermediaries subject to the GwG, to board roles in operating companies and to pure notarisation without advice (Article 2(4)(f), (4bis) and (4ter) GwG).

Financial intermediaries

From 1 April 2027 banks and other financial intermediaries must report discrepancies between the register and their own information if these cast doubt on its accuracy and the client does not resolve them within a reasonable period; the report is due within 30 days (Articles 30 and 54 TJPG). FINMA has also consulted on a partial revision of the FINMA Anti-Money Laundering Ordinance, including a duty to understand ownership and control structures; according to FINMA, entry into force is planned for the first quarter of 2027 (regulatory projects, status 1 September 2026).

Deadlines and transitional rules

For existing companies, staggered deadlines run from 1 October 2026. If a company changes its commercial register entry earlier, it must report within one month of that first change (Article 51(1) TJPG).

Note on GmbHs: the transparency register of the Federal Office of Justice interprets Art. 51(3)(d) TJPG as covering all companies that are not subject to an ordinary (full) audit under Art. 727 CO; a limited audit does not count as an ordinary audit. A GmbH with a limited audit therefore has six months (transparency register FAQ, retrieved 31 Oct 2026).

The calendar dates are calculated from the date of entry into force. Anyone who intentionally breaches reporting or information duties faces a fine of up to CHF 500,000; disregarding orders of the control office can lead to fines of up to CHF 100,000. Prosecution lies with the Federal Department of Finance (Articles 43–45 TJPG).

Tasks for banks, law firms and fiduciaries

The revision creates different work packages for each group. The following lists are a starting point for internal planning.

Banks and other financial intermediaries

• Reconcile KYC data on legal entity clients with the register by April 2027 and resolve differences.
• Define a process for client notices, deadlines and discrepancy reports, including documentation.
• Link the periodic review of client records under Article 7(1bis) GwG with the new register data; see planning KYC remediation and periodic reviews.
• Review the AML risk analysis against the clarifications in FINMA Guidance 04/2026.

Law firms

• Check mandates for whether they fall under the new adviser activities or an exemption applies.
• Apply to join an SRO and set up internal directives, identification and documentation processes.
• Add GwG checks to client intake and conflict checks, and train staff.

Fiduciaries and domicile providers

• Record domicile and registered office mandates lasting more than six months; they are now subject to the GwG.
• Prepare or file the transparency register report for administered companies where the governing body delegates the task (Article 12(2) TJPG).
• Trustees domiciled in Switzerland check their duties under Articles 15 and 16 TJPG.

Capacity and roles

The heaviest workload is likely to fall in the first twelve months: first reports for companies, building an AML framework for advisers and register reconciliation for banks. After that, the load drops to ongoing changes and discrepancy cases.

Example (assumption): register reconciliation in a bank

A bank has 5,000 legal entity clients. It allows 30 minutes per client for the reconciliation, around 2,500 hours. If 5 % of cases show discrepancies and each takes two hours for client contact and documentation, another 500 hours are added. With 1,600 productive hours per full-time employee, this is just under two FTE over a year.

Typical roles are compliance officers for directives and the SRO application, KYC analysts for reconciliation, and corporate lawyers to identify beneficial owners in complex structures. Alpinum Solutions provides these professionals through staff leasing (Personalverleih, Swiss staff leasing) and freelancing, part-time or full-time; Alpinum holds the cantonal licence for staff leasing. The company directs the work. What an interim role in a compliance team looks like is described in interim compliance officer: tasks, requirements and engagement models.

Limits and risks

• The exact entry into force of the revised FINMA ordinance is still open; FINMA plans it for the first quarter of 2027.
• Responsibility for correct reports stays with the most senior member of the governing body, even if third parties prepare them.
• Whether an activity falls under the GwG is a legal question to be assessed case by case. Alpinum is not a law firm and does not provide legal advice.
• All dates should be checked on Fedlex and with the relevant SRO before decisions are made.

Frequently asked questions about the transparency register and the AML revision

Does every GmbH and AG have to register?

In principle, yes. Companies limited by shares and limited liability companies are subject to the TJPG and must report their beneficial owners (Articles 2 and 9 TJPG). Listed companies and subsidiaries more than 75 % owned by them are exempt, as are companies at least 75 % owned by public bodies. If all beneficial owners are already in the commercial register, a longer deadline until 30 September 2028 applies.

Which advisory activities are now subject to the GwG?

The law covers anyone who professionally assists third parties with buying or selling real estate, forming, managing or administering non-operating legal entities, or buying and selling legal entities through such structures. Providing a domicile or registered office for more than six months is also covered. Lawyers' work in proceedings and transactions below CHF 5 million paid through financial intermediaries are exempt.

Who has to file the report with the transparency register?

The most senior member of the company's governing body is responsible (Article 12 TJPG). The task can be delegated to people within the company or to third parties such as fiduciaries. Responsibility for a correct and timely report, however, stays with the governing body, so delegation needs clear instructions and a check before submission.

What are the penalties for late or incorrect reports?

Anyone who intentionally breaches the duty to report to the transparency register or to the company, or provides false information, can be fined up to CHF 500,000 (Article 43 TJPG). Disregarding a final order of the control office can lead to a fine of up to CHF 100,000 (Article 44 TJPG). Proceedings are conducted by the Federal Department of Finance.

Who can see the data in the transparency register?

Online access is available to authorities and to financial intermediaries and advisers insofar as they need the data for their due diligence under the GwG (Articles 25–27 TJPG). Queries by authorities and financial intermediaries are logged. The company concerned can request a confirmation of registration or an extract (Article 28 TJPG).

Next step

If register reconciliation, the SRO application or your group's first reports require additional capacity, talk to us about scope and profiles. Selected profiles are usually available within 48 hours; the start date is agreed jointly by the company and Alpinum.

• AML, KYC and financial crime compliance: remediation and taskforces
• Interim legal and compliance support in Switzerland
• Regulatory calendar: key deadlines for Switzerland, Germany and the EU
• Discuss your requirements

Last updated: 31 October 2026.