In September 2025, the Federal Assembly enacted the Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG) and revised the Anti-Money Laundering Act (AMLA). The objective is to enhance the combat against money laundering and terrorist financing. By doing so, the Swiss Parliament resolved that companies and other legal entities shall be required to disclose their beneficial owners to the authorities as part of the efforts to combat money laundering. The national, yet non-public, transparency register is an element of the reform of the Money Laundering Act and aims to assist in the prevention of money laundering.

The TJPG will establish new transparency requirements for legal entities and create a centralized federal register of beneficial owners. This register aims to provide specific authorities with prompt and convenient access to trustworthy information regarding the beneficial owners of a legal entity. It will be administered by the Federal Department of Justice and Police. An inspection entity within the Federal Department of Finance will evaluate the accuracy, completeness, and timeliness of the data in the transparency register. The register will be available to specific authorities and individuals in accordance with the Anti-Money Laundering Act.

The latest controversy in the counter-legislative procedure pertained to the assumption of accuracy regarding entries in the transparency register. While there was unanimous consensus on the necessity for authorities to depend on the accuracy of the entries of the registry, the Federal Council and the National Council initially intended to specify that the entries were solely declarative. The Council of States, conversely, sought to incorporate a presumption of accuracy into the legislation. This would have implied that financial intermediaries could merely consult the transparency register when assessing their customers, without needing to ascertain the accuracy of the data. The established compromise now mandates that bankers and advisors, for example, may depend on the entries in the transparency register, provided that “the verification carried out with due diligence does not reveal any discrepancies” (Art. 23 (2) TJPG).

The specific obligations of legal entities and individuals mandated to consult the transparency register will be delineated in the implementing provisions of the TJPG, as outlined in the draft Ordinance on the Transparency of Legal Entities and the Identification of Beneficial Owners. The ordinance will delineate the specific information that entities are required to collect and report, elucidate specific terminology and delineate the procedure for reporting to the transparency register. The consultation period for the draft runs until 30 January 2026.