Swiss transparency Register (TJPG): obligations & deadlines

How Will the TJPG Impact Your Company?

The Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG or Legal Entities Transparency Act, LETA) introduces new obligations regarding the identification, verification, documentation and registration of beneficial owners for Swiss companies.

The legislation applies to the majority of Swiss legal entities (Ltd./SA, LLC/Sàrl/GmbH, etc.), as well as certain foreign entities with links to Switzerland. Individuals who qualify as beneficial owners must be registered in the Transparency Register.

The size of a company is not the determining factor. What matters is the company's legal structure and the way ownership or control is exercised. Even seemingly straightforward corporate structures may be subject to the new obligations introduced by the TJPG.

What Is the Transparency Register?

The Transparency Register is a central database established to collect information on the natural persons who exercise effective control over a company or who derive the principal economic benefit from it.

The register will not be publicly accessible and is intended to strengthen corporate transparency and support the fight against money laundering and terrorist financing.

What is the Transparency Register in Switzerland?

The Transparency Register is a federal database that collects information on the beneficial owners of legal entities subject to the TJPG.

Who is considered a beneficial owner?

A beneficial owner is the natural person who ultimately exercises effective control over a company or derives its principal economic benefit, whether directly or indirectly.

When can the identification of beneficial owners become more complex?

Identifying beneficial owners may become more complex in the presence of:

Multiple shareholders or quota holders;
Holding companies and affiliated entities;
Indirect ownership structures;
Corporate groups;
Shareholders resident in different jurisdictions.

In such cases, specific reviews may be required to correctly identify the natural persons who exercise control over, or derive economic benefit from, the company.

Which companies are subject to the TJPG?

Swiss legal entities

Public limited companies (SA/Ltd.)
Limited liability companies (Sagl/GmbH/LLC)
Cooperatives
Partnerships limited by shares
SICAVs
SICAFs
Limited partnerships for collective investment schemes

Foreign legal entities

With a branch registered in the Swiss Commercial Register
With effective management in Switzerland
Owning or acquiring real estate in Switzerland

Main exemptions

Listed companies and certain subsidiaries
Pension institutions subject to regulatory supervision
Companies predominantly owned by public authorities

When does the TJPG enter into force?

The law will enter into force on 1 October 2026. A pilot phase allowing voluntary early filings will be available from 17 August 2026.

What information must be reported?

Beneficial owners must be identified, verified and documented, and the information required by the legislation must be reported accordingly.

Are foreign companies subject to the TJPG?

Yes, in certain circumstances. Examples include companies with a Swiss branch, effective management in Switzerland, or real estate holdings located in Switzerland.

How can the compliance process be managed?

A preliminary review of the company's corporate structure and available documentation helps plan and manage the requirements introduced by the TJPG effectively.