Detailed provisions of Switzerland's Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (the Act) are now available, following its approval by the federal parliament on 26 September 2025.

When enacted, which is likely to be in 2027, the new statute will bring considerable changes, superseding the current rules on the identification of beneficial owners that came into effect in 2015, says law firm Walder Wyss. It will affect most Swiss companies, some legal persons governed by foreign law and trustees domiciled or managing trusts in Switzerland. It will impose significant duties on boards, shareholders, members, beneficial owners and third parties.

The directors of all such entities must identify its beneficial owners. These are principally all natural persons who ultimately control that company by shares, votes or any other way, directly or indirectly. The name, date of birth, citizenship, address, country of residence and necessary information on the nature and extent of the control exercised must be collected and kept up-to-date. This information must be submitted to the transparency register operated by the Swiss government within one month of the company’s incorporation. Shareholders or members who ultimately control the company must report their control within one month of it being established. The beneficial owner and third parties involved in the chain of control must cooperate in verifying the owner's identity and their status by providing the company, shareholders or members with the necessary information and supporting documents.

Swiss companies subject to the Act must report the information to the transparency register within one month of the first change to the commercial register entry, following the entry into force of the Act. If their beneficial owners are all registered as members or corporate bodies in the commercial register, they must report the information to the transparency register no later than two years after the Act comes into force. Different deadlines apply depending on the auditing status of the company concerned.

Legal persons governed by foreign law must report the beneficial ownership information to the transparency register and designate a representative or a domicile for service in Switzerland within six months of the Act coming into force. If their actual administration is located in Switzerland they must keep a register of their owners at their place of effective management, recording the first and last names or the company name and address of these persons.

Trustees subject to the Act must identify the beneficial owners and collect the relevant information and documents, keep records and periodically review and update the information as necessary. They are not required to report the information to the transparency register.

Only the municipality of residence will be reported to the transparency register. In any case, the register is not publicly accessible and may be accessed electronically only by selected Swiss authorities. Financial intermediaries and advisors may also be able to access it in order to fulfil their duty of due-diligence under the Swiss Anti-Money Laundering Act (the AML Act).