The case

New Reporting Obligations for Companies and Trust Structures.

The commentary

The Swiss Federal Council has adopted the implementing ordinances to the Federal Act on the Transparency of Legal Persons and the Identification of Beneficial Owners (TJPG), together with corresponding amendments to the Anti-Money Laundering Act (AMLA), which enters into force on 1 October 2026. The framework is wide in scope and provides for several exemptions.

Existing entities will benefit from transitional periods, whose length depends on their legal form and specific circumstances. Depending on the structure, initial reporting obligations may arise as early as the end of 2026 or the beginning of 2027.

Under the new regime, legal entities – in particular corporations (AG), limited liability companies (GmbH) and other legal entities – as well as trust structures will be required to identify their controlling persons respectively their beneficial owners, maintain appropriate records and report the relevant information to the newly established federal Transparency Register. Reported information must be kept accurate and updated on an ongoing basis.

For trusts, the category of beneficiaries has been aligned with the FINMA Anti-Money Laundering Ordinance and is limited to specifically identified beneficiaries. Where a trust holds an interest in a reporting entity, the beneficial ownership analysis must assess the trust structure in order to identify the ultimately controlling natural persons. Depending on the circumstances, these may include the settlor, trustees and, where applicable, protectors.

The Transparency Register will be maintained by the Swiss Confederation and will not be publicly accessible. Access will be restricted to competent authorities and certain persons and institutions subject to anti-money laundering regulations.

The new framework significantly enhances transparency and documentation requirements for ownership and control structures. Companies should review their ownership arrangements, identify beneficial owners and assess whether their governance and compliance frameworks are adequate. They may also need to strengthen internal processes and training materials in order to ensure readiness for the new obligations. Advisory firms should assess whether they fall within the scope of AMLA and, if this is the case, whether membership in a recognised self-regulatory organisation (SRO) is required.