Swiss Transparency Register: What It Means for SMEs

The Transparency Register, which will come into force in October 2026, is intended to provide clarity about the actual owners and controllers of companies. Beneficial owners must be properly identified.

The Transparency Register is intended to make opaque corporate structures more difficult and strengthen the fight against money laundering. The central question is: Who stands behind a company? This refers to the beneficial owner. These individuals must be recorded in a central register from 1 October.

Although some details concerning the implementation are still unclear, SMEs would be well advised to review their ownership and control structures now and prepare for implementation.

When Is an SME Affected?

AGs and GmbHs in particular are likely to fall under the new system. Foundations and associations, as well as listed legal entities, pension institutions and companies that are at least 75 percent owned by public authorities, are exempt from this reporting obligation.

The size of the company is not the central criterion. What matters is the legal structure and the question of who exercises how much influence – for example through shareholdings. It is therefore worth taking a closer look even where ownership structures are straightforward.

What Needs to Be Done?

SMEs should already begin identifying their beneficial owners, documenting the relevant information and keeping it up to date whenever changes occur.

This includes carefully analysing ownership interests and control structures, organising documents and establishing internal procedures for notifications and amendments. Anyone who provides incorrect information or fails to submit required notifications must expect legal consequences.

Beneficial Owner

The beneficial owner is the natural person who ultimately owns or controls a company – either directly or through several levels of ownership.

What matters is actual control, not merely the formal position. The legislator provides for a holding of at least 25 percent of the capital or voting rights.