The Transparency Act entered into force today, which means that “the transparency register has also commenced operations,” as the Federal Office of Justice (FOJ) phrased it in a slightly awkwardly worded press release. It was preceded by a pilot phase involving around 2,500 companies.

As of 1 October, “every reporting legal entity must register once in the register and report any changes regarding beneficial owners,” it says further in the finest legal German.

Combating Money Laundering and Terrorist Financing

According to the “Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners” (TJPG), this refers to those persons “who exercise control over Swiss legal entities or foreign legal entities with a connection to Switzerland — for example through their capital participation or voting rights.”

The transparency register, maintained by the FOJ, is intended to enable authorities to determine more efficiently and reliably who actually controls a legal entity. In doing so, it is meant to contribute to the fight against money laundering and terrorist financing. The FOJ writes that the register is available to authorities as well as financial intermediaries and advisers in connection with their obligations under the Anti-Money Laundering Act.

Federal Office of Justice: “Data and Information Security is the Top Priority”

The Federal Office asserts that the data and information security of the transparency register, and thus protection against cyberattacks and unauthorized access to data, is the top priority.

The new IT system runs in a specially secured network, and the data are stored exclusively on a physical server in Switzerland. In addition, the number of possible queries will be limited and secured through multi-stage authentication.

Cyber Disaster in the Principality as a Cautionary Example

The fact that these aspects are mentioned so prominently in the press release is likely also connected with the cyber disaster in the Principality of Liechtenstein in early August. An as yet unknown perpetrator gained access to the “Register of Beneficial Owners” (VwbP) and copied data from more than 30,000 entries on individuals behind foundations and companies. This also raised concerns here in Switzerland about whether it is really wise to concentrate such sensitive data in a central electronic register that is also accessible from outside.

What the FOJ does not mention, however, is that Switzerland, with the transparency act and the corresponding register, has also significantly responded — or had to respond — to international pressure for stronger anti-money-laundering efforts, particularly from the Financial Action Task Force.

A Flood of Notifications Expected

The FOJ expects a large number of notifications in the coming months. The deadlines are not the same for all reporting legal entities and range from one month to two years. “It is expected that the number of notifications will be very high, especially in the coming months.” The FOJ has also prepared from an IT perspective: “In order to preserve the capacity of the register, certain services are currently not yet fully available.” In the initial phase, there may also be occasional brief restrictions in the use of the system. 

On the transparency register website, reporting entities can find information on how to register. Webinars on the topic will also be offered from December 2026. Registration on the EasyGov platform and entry in the transparency register are free of charge, the FOJ writes.

However, the press release does not state how high the costs were for setting up the register and developing the IT systems required for it.