Since Parliament passed the TJPG (Act on the Transparency of Legal Entities and the Identification of Beneficial Owners) and amended the GwG on 26 September 2025, the key question was no longer whether, but when, the new transparency regulations would take effect. That question has now been officially answered. With its decision of 12 June 2026, the Federal Council gave the go-ahead and thereby also triggered the transition periods.
At its meeting on June 12, 2026, the Federal Council decided that the new Act on the Transparency of Legal Entities (TJPG) will take effect on 1 October 2026. This officially confirms the timeline referred to as “planned” in the original article. For companies and consultants, this date marks the actual starting point: As of 1 October 2026, the statutory transition periods for registration in the new transparency register will begin.
An important clarification regarding the original article we published on our KYC blog: The provisions concerning public notaries will not be introduced at the same time. The Federal Council has postponed their implementation to give the cantons the necessary time to adapt their own legislation. This applies exclusively to notaries employed under public law. Freelance notaries and attorneys who perform structuring activities, on the other hand, will remain fully subject to the Anti-Money Laundering Act (AMLA) as of 1 October 2026. For affected law firms, it is recommended to establish a clear internal distinction, both in terms of client classification and documentation.
With the confirmation of the date of 1 October 2026, these deadlines (pursuant to Art. 51 TJPG) can now be broken down into specific calendar dates:
|
Type of Society |
Deadline for Initial Registration |
|
Corporations Subject to Regular Auditing Requirements |
1 January 2027 |
|
Other companies subject to mandatory audits |
1 February 2027 |
|
Corporations Not Subject to Mandatory Audits |
1 March 2027 |
|
Other Legal Entities |
1 April 2027 |
|
Foreign legal entities |
1 May 2027 |
|
Companies whose beneficial owners are already registered in the commercial register |
1 October 2028 |
Foreign legal entities must also designate a representative or provide a registered address in Switzerland. Special caution is required for companies that make any changes to their entry in the Commercial Register after 1 October 2026: In such cases, the reporting deadline is reduced to one month. This applies regardless of the otherwise applicable transition period.
The Federal Office of Justice has launched a pilot program for the transparency registry. The registry is officially named TranspaReg and can be accessed at www.transpareg.admin.ch. Submissions are made exclusively through EasyGov - pre-registration is already available. The pilot program is voluntary and free of charge and will run until the TJPG takes effect, but for no longer than two years. The data can be transferred directly into the Transparency Register - thereby fulfilling the company’s reporting obligation.
Companies should begin documenting their full ownership and control structure today, identify beneficial owners in accordance with Art. 2 of the TJPG, obtain supporting documentation, and establish an internal reporting process for changes. Every entry in the commercial register made after 1 October 2026, triggers a 30-day reporting deadline.
Advisors (attorneys, notaries, trustees) must verify whether their activities exceed the new thresholds and, if necessary, join a recognized self-regulatory organization (SRO). A clear distinction between privileged (legal) and non-privileged (structuring) mandates must be documented.
Financial intermediaries must integrate the transparency register into their KYC processes as a supplementary verification source and establish an internal process to comply with the 30-day reporting requirement in the event of discrepancies with the register.
For further information or if you have any questions, please feel free to contact support@kyc.ch.
This article is intended solely for general informational purposes and does not constitute legal or compliance advice. It will not be updated and reflects our understanding as of the end of June 2026.