Switzerland Beneficial Ownership Transparency Register (TJPV): AML Compliance Guide 2026

Switzerland Introduces Beneficial Ownership Transparency Register: A New Era of UBO Transparency

Regulation Name: Ordinance on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPV)
Date Of Enforcement: 01 Oct 2026
Region: Switzerland
Agency: Swiss Federal Council (Der Schweizerische Bundesrat)

Switzerland has taken one of its most significant anti-money laundering (AML) reforms in decades with the publication of the Ordinance on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPV). The regulation establishes detailed rules supporting the Federal Act (TJPG) and introduces a centralized Transparency Register for beneficial ownership information.

The ordinance strengthens Switzerland’s framework against money laundering, terrorist financing, sanctions evasion, tax crimes, and the misuse of legal entities by requiring companies to identify, verify, maintain, and report their ultimate beneficial owners (UBOs).

For AML compliance leaders, financial institutions, regulated businesses, and multinational organizations operating in Switzerland, the regulation represents a major operational shift that will impact customer due diligence (CDD), enhanced due diligence (EDD), beneficial ownership verification, and ongoing monitoring.

Why Did Switzerland Introduce the TJPV?

Global regulators, including the FATF, have increasingly emphasized transparency around legal ownership structures.

Complex corporate structures, trusts, nominee arrangements, and layered ownership have long enabled criminals to conceal the true owners of assets.

The TJPV seeks to address these vulnerabilities by:

• Creating a centralized transparency register
• Standardizing beneficial ownership identification
• Defining direct and indirect control
• Introducing reporting obligations
• Enabling financial intermediaries to verify ownership information
• Improving information sharing with competent authorities

The regulation becomes effective 1 October 2026.

Key Objectives of the Regulation

The ordinance aims to:

• Increase legal entity transparency
• Improve beneficial ownership identification
• Reduce anonymous corporate structures
• Support AML investigations
• Improve sanctions compliance
• Strengthen customer due diligence
• Enhance corporate governance
• Facilitate regulatory supervision

What Is the Swiss Beneficial Ownership Transparency Register?

The Transparency Register is a centralized database that stores information about:

• Legal entities
• Beneficial owners
• Ownership structures
• Control chains
• Trust relationships
• Reporting history
• Corrections and amendments
• Compliance status

Unlike a public corporate register, access is restricted to:

• Competent authorities
• Financial intermediaries
• Certain advisers subject to AML obligations

This allows regulated institutions to verify beneficial ownership during onboarding and periodic reviews while maintaining appropriate privacy safeguards.

Who Must Report?

The regulation applies to:

• Swiss legal entities
• Certain foreign legal entities with reporting obligations
• Shareholders with reporting duties
• Financial intermediaries
• AML-regulated advisers

Foreign entities meeting specified Swiss nexus criteria must also report beneficial ownership information.

How Switzerland Defines a Beneficial Owner

The TJPV introduces detailed criteria for determining beneficial ownership.

1. Direct Ownership

A person directly controls a legal entity when they hold at least 25% of:

• Share capital, or
• Voting rights.

This ownership must not be held through intermediate entities.

2. Indirect Ownership

Control also exists when ownership is exercised through intermediate companies or trusts.

Generally, a person indirectly controls an entity when they own more than 50% of one or more intermediary entities that themselves hold at least 25% of the target entity.

3. Control Through Other Means

Ownership is not the only determining factor.

The regulation recognises control where an individual can:

• appoint or remove the majority of directors;
• exercise veto rights over strategic decisions;
• influence budgets or financing;
• control profit distributions;
• exercise influence through shareholder agreements;
• exercise rights through options, convertible instruments or similar arrangements;
• control via trusts or fiduciary relationships.

This aligns closely with FATF’s principle that beneficial ownership extends beyond shareholding percentages.

Treatment of Trusts

The ordinance contains comprehensive provisions for trusts.

Information must be collected regarding:

• trustees;
• beneficiaries;
• settlors;
• individuals exercising ultimate control;
• discretionary trusts;
• trust control chains.

This closes a common transparency gap frequently exploited in complex ownership structures.

Information Companies Must Collect

Entities must obtain detailed information on beneficial owners, including:

• Full name
• Date of birth
• Nationality
• Country and municipality of residence
• Swiss social security number (where applicable)
• Passport or identity document where necessary
• Nature of control
• Whether control is direct or indirect
• Whether control is exercised individually or jointly
• Ownership percentage bands (25–50%, >50–75%, >75%)

Where complex ownership chains exist, information on intermediary companies, trusts, and fiduciary relationships must also be maintained.

Reporting Requirements

Companies must report:

• Company identification details
• Beneficial ownership information
• Nature of control
• Ownership thresholds
• Control chains
• Trust information where relevant
• Reporting person’s details

If beneficial owners cannot be identified or verified despite reasonable efforts, entities must report available information together with details of the senior managing official acting as the contact person.

Electronic Filing System

The TJPV establishes a primarily electronic reporting framework.

Entities must:

• authorize at least one representative;
• authenticate through approved identity systems;
• submit reports electronically;
• obtain or use a Swiss UID where required.

API-based interfaces are also envisaged to facilitate electronic submissions.

Simplified Reporting for Certain Companies

To reduce administrative burden, simplified reporting procedures apply to:

• single-shareholder companies;
• certain limited liability companies meeting prescribed conditions.

These entities can confirm ownership using streamlined reporting rather than submitting the full dataset.

Ongoing Reporting Obligations

Companies must keep information current.

Updates are required whenever reportable information changes, including when ownership crosses regulatory thresholds.

Some administrative updates are synchronized automatically with other Swiss government databases, reducing duplicate reporting.

Access for Financial Institutions

The Transparency Register is designed to support AML compliance.

Authorized users include:

• AML supervisors
• Financial intermediaries
• Certain regulated advisers
• Competent authorities

Users may search the register to verify legal entities and beneficial ownership information during customer onboarding and ongoing due diligence.

Mandatory Discrepancy Reporting

A notable feature of the regulation is the obligation for financial intermediaries and authorities to report discrepancies where register information appears inaccurate or incomplete.

Examples include:

• missing beneficial owners;
• incorrect ownership percentages;
• inaccurate control information;
• outdated records;
• absent register entries.

This creates an ongoing feedback mechanism to improve data quality.

Risk-Based Supervision

The supervisory authority will classify entities into:

Risk-based inspections and sampling will prioritize higher-risk entities.

Key Compliance Implications for AML Teams

Financial institutions should prepare to:

• Update beneficial ownership procedures.
• Integrate Transparency Register checks into onboarding.
• Enhance control-chain mapping.
• Improve trust ownership verification.
• Establish discrepancy reporting workflows.
• Strengthen ongoing ownership monitoring.
• Update customer risk assessment methodologies.
• Train AML investigators and onboarding teams.

What This Means for Global AML Compliance

The TJPV places Switzerland alongside jurisdictions that have adopted centralized beneficial ownership registers in response to international transparency standards. For multinational financial institutions, it introduces an additional authoritative source for verifying UBO information, but also new expectations around discrepancy reporting, control-chain analysis, and ongoing monitoring.

Compliance functions should review onboarding workflows, KYC policies, and screening technologies to ensure they can ingest register data, identify complex ownership structures, and document investigations efficiently.

How ZIGRAM Helps

As beneficial ownership regulations become more sophisticated, compliance teams require more than manual corporate registry checks.

ZIGRAM helps organizations strengthen beneficial ownership compliance by:

• Screening customers against global watchlists and sanctions.
• Performing automated KYC and risk-based onboarding with PreScreening.io.
• Conducting enhanced due diligence using Due Diliger.
• Monitoring adverse media and corporate developments through Dragnet Alpha.
• Supporting risk-based AML programs with comprehensive entity intelligence.

These capabilities enable institutions to adapt to evolving transparency requirements while reducing manual effort and improving audit readiness.

Frequently Asked Questions

When does the Switzerland TJPV come into force?

The ordinance enters into force on 1 October 2026.

What is the ownership threshold for identifying beneficial owners?

A direct ownership interest of 25% or more of share capital or voting rights generally qualifies as beneficial ownership, alongside other forms of control.

Can someone be a beneficial owner without owning shares?

Yes. Individuals exercising effective control through contractual rights, governance powers, trusts, or other arrangements may qualify as beneficial owners.

Must financial institutions report discrepancies?

Yes. Financial intermediaries are required to report qualifying discrepancies identified between their due diligence findings and the Transparency Register.

Who can access the Transparency Register?

Access is available to competent authorities, financial intermediaries, and certain regulated advisers, rather than the general public.

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