ComplyFactor provides Swiss Transparency Register compliance services for businesses preparing to identify, verify and report beneficial owners, map direct and indirect ownership structures, and build a repeatable process for keeping ownership information current.
Swiss entities, and certain foreign entities with a Swiss nexus, identify and report their beneficial owners to a new federal register.
Switzerland's new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners will enter into force on 1 October 2026, introducing a central federal Transparency Register of the beneficial owners of Swiss legal entities and certain foreign entities with a Swiss nexus. For businesses in scope, this is a new, standalone compliance obligation, separate from existing AML/KYC duties, that requires identifying beneficial owners, documenting how control is exercised, and reporting that information within an applicable transitional deadline.
ComplyFactor helps affected businesses work through that process: assessing whether an entity falls within scope, mapping ownership and control through direct holdings, indirect chains and other forms of control, preparing the information a report requires, and building a process to keep that information current once submitted. This includes fintech companies, payment businesses, financial intermediaries, fiduciary businesses, holding structures, family-owned companies, corporate groups with layered ownership, and foreign entities with a qualifying Swiss connection.
This service sits alongside ComplyFactor's wider AML & Regulatory Compliance Services in Switzerland, and connects to our Swiss AML Gap Analysis and AML & Regulatory Compliance Advisory services where broader AML program work is needed.
The Transparency Act applies, in principle, to Swiss stock corporations (AG), limited liability companies (GmbH), partnerships limited by shares, cooperatives, and certain Swiss collective-investment companies (including SICAV and SICAF structures), along with certain foreign legal entities that have a qualifying Swiss connection, including a registered Swiss branch, an effective place of management in Switzerland, or ownership of Swiss real estate.
Not every Swiss entity is in scope. Current guidance excludes, among others: listed companies and entities in which a listed company or public body holds a sufficiently large stake, supervised pension institutions, associations, foundations, and sole proprietorships.
Reporting scope depends on the legal form and specific facts. This table is a practical overview, not a substitute for fact-specific legal analysis.
Illustrative only — federal Transparency Register rules apply uniformly across Switzerland; there is no canton-specific variation.
A beneficial owner under the new Swiss framework must ultimately be a natural person, never a company, trust, or other structure in its own right. Control can arise in more than one way, and the law does not reduce it to a single test.
The core threshold is that a natural person who, alone or together with others, holds at least 25% of the capital or voting rights of an entity is a beneficial owner. But equity and voting ownership are not the only route: a person who controls the entity by other means, for example through governance rights, contractual arrangements, or coordinated action with others, can also meet the definition, even where their direct shareholding sits below 25%.
Where ownership runs through one or more intermediate entities, the chain has to be traced through each layer until the natural person or persons who ultimately hold that level of control are identified. Where an entity is genuinely unable to identify a beneficial owner after appropriate enquiry, the law provides a fallback: the entity's most senior governing-body member is generally recorded instead, together with a record of the enquiries made.
A natural person holds 30% of the shares directly.
A natural person controls a parent that holds the Swiss entity.
Voting or contractual rights determine key decisions.
Two or more people, acting alone or in concert, each qualify.
A current shareholder register is rarely the full picture. Parent-subsidiary chains, foreign holding companies, multiple intermediary entities, cross-shareholdings, and contractual control arrangements can all sit between an entity and the natural person who ultimately controls it, and a structure that looks straightforward on paper can still route control somewhere unexpected once each layer is traced.
ComplyFactor maps that chain: identifying each intermediate entity, tracing ownership and voting rights through it, and working out where genuine control ultimately lands. The beneficial owner identified at the end of that chain is always a natural person. The output is a defensible record of how the beneficial owner or owners were identified, not just a name.
For each identified beneficial owner, current guidance requires reporting: name, date of birth, nationality, and address and country of residence, together with the nature and extent of the control exercised. ComplyFactor helps collect, verify and structure this information before it is submitted, so the first report is accurate rather than needing correction afterwards.
Businesses should also expect to demonstrate how the information was verified, not just what it says. Entities that cannot identify or verify a beneficial owner despite reasonable enquiry are expected to record that fact along with the steps taken.
ComplyFactor's Transparency Register engagements generally follow the same structure, scoped to what an entity actually needs.
Reports to the Transparency Register are submitted electronically, primarily through the EasyGov.swiss platform, the Swiss federal government's central portal for company administration. Businesses can register on EasyGov in advance of needing to file, which reduces friction once a report is actually due. Under defined conditions, some entities may also be able to report through the commercial register instead.
Where an entity authorises a third party, such as an adviser, to prepare or submit on its behalf, that access needs to be properly authorised through the applicable EasyGov procedure. ComplyFactor supports the preparation and readiness work behind that submission, without acting as the entity's registered government account holder and without being an official EasyGov provider.
Reporting is not a one-time filing. Once information is on record, the entity remains responsible for keeping it current, which means detecting ownership or control changes, collecting updated evidence, and submitting an update within the applicable timeframe once a change occurs. ComplyFactor helps build that process: assigning internal responsibility for monitoring ownership changes, setting an escalation path when a change is identified, and keeping the update workflow aligned with the entity's broader corporate and compliance records.
Foreign legal entities are not automatically in scope. Current guidance brings a foreign entity into scope only in specific circumstances. ComplyFactor helps foreign groups with a Swiss presence confirm whether any of these circumstances apply, and if so, prepares the beneficial-ownership identification and reporting work on the applicable timeline.
A branch registered in the Swiss commercial register.
The entity's actual place of management is in Switzerland.
The entity owns or acquires Swiss real estate.
Transparency Register reporting and AML/KYC beneficial-owner identification are related but not identical obligations, and they don't always draw the line in exactly the same place.
Entity-level beneficial-owner identification reported to the federal register under the Transparency Act.
Customer and beneficial-owner identification maintained for AML compliance purposes.
Authorised financial intermediaries and authorities may report discrepancies in Transparency Register information through the applicable statutory process, so keeping ownership and control information consistent across corporate records, compliance files, KYC records, and the register itself reduces the chance of that happening in the first place. ComplyFactor helps reconcile ownership information across these records and keep the documentation consistent, without duplicating a full AML program review — for broader AML control work, see our Swiss AML Gap Analysis service.
Tracing cross-border and multi-layered ownership chains, not stopping at the shareholder register.
Documenting how each beneficial owner was identified so the record holds up if questioned.
Experience with foreign holding companies and layered corporate groups.
A repeatable process for keeping information current, not just a first filing.
Keeping ownership information consistent across a business's compliance framework.
ComplyFactor is not the Swiss Transparency Register, the Federal Office of Justice, or any other Swiss government authority, and is not an official EasyGov provider. ComplyFactor cannot guarantee that a filing will be accepted without query, and does not issue legally binding determinations of beneficial-ownership status. Where a structure raises a genuine legal-interpretation question, we say so and recommend qualified Swiss legal counsel.
No. The Transparency Register is not publicly searchable and access is restricted by law to specified government authorities and, for defined anti-money-laundering due-diligence purposes, to financial intermediaries and advisers subject to the AMLA. A reporting entity can obtain confirmation of its own registration and, where available under the official procedure, request an extract of its own register information.
Yes. Mapping multi-layered, cross-border, and indirect ownership structures to identify the natural person or persons who ultimately control an entity is a core part of this service.
Preparation support is available regardless of who submits. Submission itself is made through EasyGov, and a third party can act on an entity's behalf where properly authorised through the applicable procedure. ComplyFactor is not an official EasyGov provider and does not submit as though it were the entity's own government account.
Responsibility for the report lies with the entity's most senior governing-body member under the applicable rule.
Day-to-day preparation and submission can be delegated internally or to an external adviser, but delegation does not remove the senior governing-body member's underlying responsibility for the report being made correctly.
Yes, in one specific situation: where an entity's beneficial owners are already recorded in the commercial register as shareholders or governing-body members, and no change to that commercial-register entry is pending, the entity can confirm that information to the Transparency Register through a simplified procedure, within an extended transitional deadline. Entities that don't meet both conditions follow the standard identification and reporting route instead.
Submitting, amending or removing beneficial-owner information, and obtaining confirmation of an entity's own registration, are free of charge. A register extract and certain formal decisions from the register or control authority are fee-based.
Whether you are confirming whether an entity falls within scope, tracing indirect ownership, preparing beneficial-owner information or building a process to keep that information current, ComplyFactor can help turn the new Swiss requirements into a practical reporting and governance workstream.