Swiss Transparency Register from 1 October 2026: What you should prepare for EasyGov now
Update of 7 October 2026: The Swiss Transparency Register has been in force since 1 October 2026. Who your beneficial owners are and what the register means for your KYC processes is covered in Part 2.
The Swiss Transparency Register will enter into force on 1 October 2026. Companies within scope will be required to report their beneficial owners – generally electronically via EasyGov. For portfolio managers under Art. 17 FinIA and managers of collective assets under Art. 24 FinIA, it is worth preparing the technical setup now: the time-critical step is not the filing itself, but linking your company to your EasyGov account.
What changes from 1 October 2026?
Once the new rules enter into force, companies within scope must report their beneficial owners within the applicable deadlines. Existing companies benefit from transitional periods – so no filing is required on 1 October itself.
The filing is generally made electronically via EasyGov. Registration is free of charge, and the register is not public: access is available to authorities as well as financial intermediaries and advisers under the AMLA.
Which deadlines apply to portfolio managers and managers of collective assets?
The applicable deadline depends on the legal form and audit regime. For managers of collective assets, the annual financial statements are audited in accordance with the principles of an ordinary audit; accordingly, the shorter transitional periods apply.
| Institution | Transitional period from 1 October 2026 | Recommended target date |
| Manager of collective assets (Art. 24 FinIA) – company limited by shares (AG) | 3 months | 31 December 2026 |
| Manager of collective assets (Art. 24 FinIA) – limited liability company (GmbH) or other legal form | 4 months | 31 January 2027 |
| Portfolio manager (Art. 17 FinIA) – AG without a statutory ordinary audit, in particular with a limited audit or opting-out | 5 months | 28 February 2027 |
| Portfolio manager (Art. 17 FinIA) – limited liability company (GmbH) subject to a limited audit | individual assessment required | provisionally 31 January 2027 |
Special case: If all beneficial owners are already entered in the Commercial Register as shareholders or members of a governing body, the transitional period is two years – our conservative target date is 30 September 2028. However, an earlier change to the Commercial Register also triggers the one-month filing deadline.
Two points should be noted: for a limited liability company of a portfolio manager subject to a limited audit, the wording of the law is not entirely clear; until this has been clarified, we recommend filing by the end of January 2027 as a precaution. Where a portfolio manager is subject to a statutory requirement for an ordinary audit, the shorter transitional periods apply: three months for an AG and four months for another legal form. A voluntary ordinary audit (opting-up) does not, by itself, trigger these shorter transitional periods.
The law specifies periods in months rather than specific calendar dates. The target dates above have therefore deliberately been calculated conservatively.
Takes precedence over all transitional periods: the first change to the Commercial Register
If you make your first change to the Commercial Register after 1 October 2026, this generally triggers a filing deadline of one month from that change. Typical examples include changes to the board of directors, new signing authorities, a change of registered office, or changes to the company name, capital or articles of association. A change in management is only relevant if it actually results in a change to the Commercial Register, for example because a signing authority is registered.
Thereafter, if any information concerning the beneficial owners changes, the change must be reported within one month after the company becomes aware of it.
Why it makes sense to prepare EasyGov now
The regular filing process for the Transparency Register will be available from 1 October 2026. However, the technical setup can already be completed in advance – and this is what determines whether the eventual deadline will be comfortable or tight.
You need three things: a personal AGOV login for the responsible person, an EasyGov account, and the link between your company and the EasyGov account via its UID.
The time-critical step
An existing goAML account is not sufficient – it is a separate account and is not a government login. For EasyGov, you need a personal AGOV login as well as an activated link to your company. Even if you are already authorised to sign for the company according to the Commercial Register, EasyGov may require a power-of-attorney or validation process when the company is linked for the first time. This process links your personal AGOV/EasyGov account to the company; it is a technical activation of your access, not a step that first creates authority to represent the company. If a power-of-attorney letter is required, it is sent to the company's registered office and must be signed in accordance with the signing authority recorded in the Commercial Register and returned. A person with sole signing authority can therefore sign it themselves. According to EasyGov, this process may take up to 14 days.
At the same time, you can already determine the beneficial owners and compile the required information.
How to link your company via EasyGov
- Log in or create an account. On easygov.swiss, select “Log in” if you already have a government login. Otherwise, select “Register” and create an AGOV account: confirm your email address, set up the login factor, enter your personal details and complete the account settings. For a new registration, we recommend AGOV. Existing CH-LOGIN accounts can currently still be used for EasyGov.
- Add the company. After the first login, the cockpit is empty. Select “Click here to get started”.
- Select government services for a company. Choose “I would like to use government services for a company …” and confirm with “Next”.
- Link an existing company. Choose “I would like to link an existing company … or apply for a UID”.
- Select the registered office. Choose “in Switzerland, Liechtenstein”.
- Search for and link the UID or company. Enter the UID in the format CHE-XXX.XXX.XXX or the company name and select “Search”. Check the company name, registered office, legal form and UID in the search result and select “Link”.
- Complete validation and the power of attorney. Wait for approval. If EasyGov requires a power-of-attorney or validation process, this serves to link your personal account to the company; it does not create authority to represent the company. If a power-of-attorney letter is sent to the registered office, sign it in accordance with the signing authority recorded in the Commercial Register and return it; a person with sole signing authority can do this themselves. The company will then appear in your cockpit.
- File from 1 October 2026. In the cockpit, select the relevant company in the top right-hand corner and start the process “Report beneficial owners”.
Our recommendation: Authorise a second person as a deputy. This ensures that you remain able to act during absences or personnel changes.
What information should you have ready for the filing?
- Company name, legal form, registered office and UID
- For each beneficial owner: first name and surname, date of birth and nationality/nationalities
- For each person: postcode, municipality of residence and country of residence
- Confirmation whether an OASI/AHV number exists; if not, a copy of a permitted identification document such as a passport, identity card or foreign national's identity document
- Whether control is exercised directly or indirectly
- Where control is exercised through an ownership interest: the applicable range of 25–50%, over 50–75%, or over 75%
- Other forms of control and the relevant arrangements, such as shareholders' agreements
- Documentation of the ownership and control structure
- If no natural person meets the relevant criteria: details of the highest-ranking member of the governing body
- Internal documentation of the assessments performed
Where control is based on an ownership interest, the relevant range is sufficient; the exact percentage does not need to be reported.
Filing since 1 October 2026
Since 1 October 2026, filings can be made via EasyGov. How to identify your beneficial owners – with typical portfolio manager structures – and what the register means for your KYC processes is explained in Part 2.
Our conclusion
The filing itself is relatively straightforward – the more important issue is timing. Three points should remain on your radar: your individual transitional deadline, the overriding rule triggered by the first change to the Commercial Register, and the lead time of up to 14 days for linking the company to EasyGov.
Once the EasyGov link is in place, only the actual filing remains to be completed.
We are happy to assist with determining the applicable filing deadline, identifying the beneficial owners and preparing the filing.
