On 26 September 2025, the Swiss Parliament adopted the new Federal Act on the Transparency of Legal Entities, introducing a central register of beneficial owners (UBO Register) to be administered by the Federal Office of Justice.
The register will cover legal entities domiciled in Switzerland as well as certain foreign vehicles with a Swiss nexus.The entry into force is expected around 2027.
Companies will be required to collect, verify, and continuously update information on their beneficial owners and to report any changes within statutory deadlines.
Violations of these obligations may lead to administrative sanctions.
This legislative development is highly relevant for financial institutions and corporate entities, as it will require the establishment of internal UBO registers and the implementation of clearly defined data-collection, verification, and reporting processes.
The new requirements represent a major step in enhancing corporate transparency and aligning Switzerland with international AML and transparency standards.
For asset managers under Art. 17 FINIA (portfolio managers) and managers of collective assets under Art. 24 FINIA, several practical and supervisory implications arise:
- Enhanced due diligence obligations:
The existing AML duties to identify and verify beneficial owners will be supplemented by the new register obligation. Asset managers must ensure that their internal KYC and AML procedures (data collection, verification, update, and documentation) are fully aligned with the new UBO Register requirements.
- Responsibility as legal entity:
If the asset manager itself is organised as a corporation (AG) or limited liability company (GmbH), it is directly subject to the reporting obligation and must record and register its own beneficial owners (e.g. shareholders, partners).
The introduction of the UBO Register marks a significant expansion of transparency and compliance obligations in Switzerland.
Financial institutions and corporate entities should prepare for the new reporting duties by reviewing and adjusting their internal control systems (ICS), AML frameworks, and KYC documentation processes. Early alignment with the register’s requirements will help mitigate regulatory risks and ensure compliance once the law enters into force.
