The Technical and Policy Sub-Committee of the STEP Swiss and Liechtenstein Association submitted comments on the proposed regulations to complement the legislation of 25 September 2025 which will lead to UBO registration in Switzerland.
\nAttached you will find a briefing note on the submissions. The final regulations are expected to be published in April to be effective in the second semester 2026. There are links to the legislation and proposed regulations in the attached briefing note.
\nSome of you will already be well-acquainted with the proposed regulations. For others, you may need to focus on the implications which may affect you/your colleagues, your clients, other service providers and investments in Switzerland.
","content":"Briefing for STEP Members in Switzerland and Liechtenstein: Swiss Beneficial Ownership Register Legislation (Enacted 25 September 2025; Anticipated effective by 30 June 2026)
\nBackground
The Swiss and Liechtenstein STEP Federation (STEP SLSF) represents the interests of members of branches in Basel, Geneva, Lausanne, Lucerne/Zug, Lugano, Zurich and Vaduz. STEP SLSF submitted a consultation response in January on the draft regulations. The final regulations are expected to be available in the second quarter of 2026, with an anticipated implementation date of 30 June 2026.
Whilst we welcome the objectives towards increased transparency and strengthening Switzerland’s anti-money laundering provisions, and so its international position as a financial centre, we have concerns that aspects of these provisions could pose significant challenges for financial intermediaries, lawyers, trustees, corporate service providers, and trust companies in their actual implementation.
\nThis briefing note is a summary of the key elements of the new legislation, as well as the draft regulations of which significant change is not expected. A response to the consultation on the draft regulations is expected in early April, and we will keep members updated on developments.
\nSummary of Key Elements
\nCorporate Entities
Applies to Swiss companies, and foreign companies ‘managed’ in Switzerland, having a permanent establishment in Switzerland or owning Swiss real estate. Both are required to register and report ownership. ‘Managed’ is not yet defined. It is possible to appoint a representative, but the company remains responsible for all data reported on its behalf. There are exceptions for listed companies and their subsidiaries.
Extensive Documentation
Documentation required to be obtained and kept by the company include copies of passports and proof of address, for all reportable individuals. This documentation is subject to audit by the authorities.
Full Chain of Control
The regulations require reporting not only on the ultimate beneficial owner, but the whole intermediate chain of control, where there is a more than a 25% interest (being ownership or control by other means). This includes the name and tax reference number of intermediate holding companies.
Trustees
Trustees subject to the Swiss AMLA (GwG/LBA 1997) are not required to register and report ownership/control of the trusts they manage (subject to the point below) but must keep the information collected pursuant to the AMLA. Other Swiss trustees who are not subject to Swiss AMLA, or foreign trustees who manage trusts in Switzerland and are not subject to Swiss AMLA, are required to collect information under the new legislation.
Reporting on Trusts
In cases where 25% or more of the company’s shares/control are held through a trust, all identified beneficiaries must be reported (regardless of whether a minor, or in receipt of a distribution).
Lawyers as Advisors
A new designation of legal work, requiring registration with an SRO as well as new compliance with AML regulations on identification of clients. This is specifically focussed on advice on the creation of corporate structures and purchase of real estate; there is currently a lack of clarity on privileged activities.
Provision of Domicile Services
A new designation of provision of domicile services, requiring registration with an SRO; there is currently a lack of certainty on exactly which services are caught.
Reporting Changes
All changes in the ownership/control structure (including changes in trust beneficiaries) must be reported within 30 days.
Reporting Discrepancies
On an intermediary checking the database, for example for a new client, any discrepancies identified must be notified within 30 days.
Risk Categorisation
Risk categorisation for all entities by the control agency with a range of four levels from ‘low risk’ to ‘very high risk’. Details on the criteria have not been published. However, the reporting of a discrepancy will automatically increase risk categorisation.
Reporting Platform
In very simple ownership structures, the company will be able to provide the information to the cantonal corporate registry. In more complex cases the reporting will be on a platform, which is currently being trialled; access will be via the easygov login and early registration is available at Transparenzregister - easygov.swiss.
Information Sharing
The enabling amendments to other regulations provide for extensive information between all governmental bodies.
Access to Database
All intermediaries subject to AML will have access to the database. There are no provisions for public access (including by investigative journalists). Use will be monitored by the authorities for misuse.
Fines
Fines of up to CHF 500k for intentional violations of reporting requirements.
This is only intended to be a summary of key points, for further details of all changes, please refer to the legislation and draft regulations, the links are below.
\nLegislation
\nFederal Act on the Transparency of Legal Entities and the Identification of Beneficially Entitled Persons
\nBundesgesetz über die Transparenz juristischer Personen und die Identifikation der wirtschaftlich berechtigten Personen (TJPG)
\nLoi fédérale sur la transparence des personnes morales et l’identification des ayant droit économiques (Loi sur la transparence des personnes morales LTPM)
\nLegge federale sulla trasparenza delle persone giuridiche e sull’identificazione degli aventi economicamente diritto (Legge sulla trasparenza delle persone giuridiche LTPG)
\nThe legislation can be found at:
\n\nThe legislation is available in German, French and Italian at this link (the options to toggle are on the top right of the page).
\nRegulations
The draft regulations can be found with the consultation documents at:
https://fedlex.data.admin.ch/eli/dl/proj/2024/97/cons_1
\nThe regulations are available in German, French and Italian at the above link.
\nMembers attention is particularly drawn to the appendix at the end of the consultation document, showing various examples of how the reporting is expected to apply in various situations.
\nProduced by the Swiss and Liechtenstein STEP Federation
16 March 2026