What the TJPG means for legal entities

Swiss Transparency Register

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  • Insight
  • 7 minute read
  • 22/01/26
Lisa Cornwell

Lisa Cornwell

Partner, Leader Private Clients and Family Offices, PwC Switzerland

Matthias Staubli

Matthias Staubli

Director, Financial Services, PwC Switzerland

Switzerland is establishing a central transparency register for the beneficial owners of legal entities under the TJPG. This consolidates and significantly tightens existing requirements to better prevent misuse. Switzerland is aligning with international standards.

What it is about

On 26 September 2025, the Swiss Parliament adopted the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG), which consolidates and strengthens Switzerland’s existing corporate transparency rules. Previously, the relevant provisions were spread across the Swiss Code of Obligations, the Federal Act on International Administrative Assistance in Tax Matters, and the Swiss Criminal Code. The core objective of the TJPG is to ensure that competent authorities can swiftly and efficiently identify the beneficial owners who ultimately exercise control over Swiss entities and certain foreign entities with a sufficient nexus to Switzerland. The transparency register paves the way for a significantly stricter transparency and AML regime and introduces new obligations for legal entities in Switzerland.

Introduction of the new reporting obligations is planned for mid‑2026; the precise date still must be determined by the Federal Council.

Why these changes are happening

The initiative is driven by the current AML framework, which affords authorities only limited access to information on beneficial owners. The new legislation is intended to strengthen Switzerland’s framework for combating money laundering and terrorist financing while also meeting international standards, such as the revised FATF Recommendation 24 and the guidelines of the Global Forum.

Who is affected

The focus typically includes Swiss corporations and partnerships (e.g., AGs and GmbHs), collective investment vehicles, holding, financing and special-purpose entities, as well as foreign legal entities with substantial Swiss nexus (e.g., a branch, place of effective management, or Swiss real estate). Structures involving fiduciary or trust elements and family office setups are also relevant.

Whether and how a particular structure falls within scope—and the extent to which any exemptions might apply—depends heavily on the specific circumstances. A brief, structured assessment provides clarity.

Who can access the register

The transparency register will not be publicly accessible. Access is limited to competent authorities and the persons specified in Articles 26 and 27 TJPG for specific statutory tasks. Obliged entities subject to due diligence requirements (e.g., financial intermediaries or advisers) will also have access to the register in the course of fulfilling their obligations.

Swiss competent authorities will additionally have access in order, among other things, to respond to requests from other countries under international administrative assistance in tax matters.

What affected legal entities must do

Under the TJPG, affected legal entities must identify their beneficial owners and verify and document this information—including the nature and extent of control—with appropriate diligence. This information must be reported to the new transparency register, which will be maintained by the Federal Office of Justice (FOJ).

The draft ordinance defines the concepts of “control” and “beneficial ownership” in detail. Reporting is free of charge.

Where the complexity lies

Three building blocks are central: robust identification of beneficial owners; traceable documentation of the identification and its basis; and reporting of key information on beneficial owners to the register.

In multi‑layered ownership, family, or trust structures, indirect control, joint influence, and control via governance bodies or contracts can trigger complex assessments, with touchpoints to AML/KYC, tax, and corporate governance.

How PwC can help

The new transparency regime will pose complex implementation and interpretation questions for many companies and structures. If you are responsible for investment vehicles, family office structures, holding companies, or operating companies with a Swiss nexus, now is a good time to place the TJPG on your agenda and plan next steps. We would be pleased to discuss further.

Contact us

Lisa Cornwell

Partner, Leader Private Clients and Family Offices, PwC Switzerland

+41 58 792 25 93

Email

Matthias Staubli

Director, Financial Services, PwC Switzerland

+41 58 792 19 23

Email