The transitional period is only part of the answer.
The TJPG entered into force on 1 October 2026. The following periods apply to entities that already existed. The check shows precautionary planning dates before the corresponding day of the month.
Initial report by existing legal entities, without an earlier commercial register amendment
Situation
Transitional period
Plan by
All beneficial owners registered in the commercial register as shareholders or members of a governing bodyArt. 51 para. 2 TJPG ↗
Other company without an audit requirement / with valid opting-out; other legal entities within scopeArt. 51 para. 3 let. d TJPG ↗
6 months
31 March 2027
Foreign legal entity already subject to the ActArt. 53 TJPG ↗
6 months
31 March 2027
Commercial register amendment
An amendment can shorten the deadline.
For an existing Swiss legal entity, the first amendment to its commercial register entry after the Act entered into force triggers a one-month period. The report must in any event be filed within the otherwise applicable transitional period.
One month from registration or becoming subject to the Act.
For new Swiss companies, the one-month period runs from registration in the commercial register. For foreign legal entities, the relevant event is becoming subject to the Act through their connection with Switzerland.
The transitional periods start when the Act enters into force on 1 October 2026. For precautionary planning, the check uses the last day before the corresponding day of the month: for example, 31 December 2026 for a three-month period. These are planning dates, not a definitive legal determination of the last permissible reporting day.
For a one-month period triggered by an individual event, one calendar month is added to the date given. If the corresponding day does not exist in the following month, its last day is used. Possible extensions for weekends or public holidays are not included. A later commercial register amendment does not extend a period that is already running or has expired.
For companies other than an AG that are subject to a limited audit, the wording of Art. 51 para. 3 TJPG does not clearly determine the applicable period. In these cases, and for special investment-related legal forms, the check flags the need for review and provides a precautionary planning recommendation. Uncertain information may conceal an earlier deadline.
Good to know
Every report starts with a thorough assessment.
Who qualifies as a beneficial owner?+
The relevant persons are individuals who ultimately control at least 25 per cent of the capital or votes, directly, indirectly or jointly with third parties, or who otherwise control the company. This may include special appointment or veto rights. Only where no individual meets any of these criteria does the statutory fallback identification of the most senior member of the governing body apply.
Art. 4–6 TJPG ↗Is registration in the commercial register sufficient?+
The existing registration of all beneficial owners may justify the two-year period. However, it does not automatically replace reporting to the transparency register. A simplified reporting procedure is available for certain limited liability companies and single-shareholder companies limited by shares; its conditions must be checked separately.
Responsibility rests with the most senior member of the governing body. The practical work may be delegated, but responsibility for proper reporting remains. Electronic reports are filed through EasyGov using a personal AGOV account and the necessary authorisations. Official registration is free of charge; legal assistance is a separate service.
If a fact recorded in the transparency register changes, the change must be reported within one month of becoming aware of it. Assign responsibilities and establish a process for this. This check covers the initial report; it does not confirm an existing entry or compliance with ongoing obligations.
I assist boards of directors, executive management teams and companies with the legal assessment of ownership and control structures, the required documentation and the preparation of reports.
This check provides non-binding guidance based on your information. It does not replace an assessment of your individual case, identify beneficial owners or send a report to the transparency register.