Switzerland’s new Transparency Register takes effect on 1 October 2026, but this is not everyone’s filing deadline. The register is not public, and obligations apply to foreign-owned Swiss companies too. Understand your deadline, the information required and Alpine Capital’s filing service: CHF 250 plus VAT for qualifying existing clients, CHF 390 plus VAT for qualifying new clients, and individual quotations for complex structures.
You own a Swiss company, perhaps while living abroad. Your Swiss director handles local administration, and your bank already has your passport and ownership documents.
Do you still need to do anything when Switzerland’s new Transparency Register takes effect on 1 October 2026?
Generally, yes. Your company must arrange a separate beneficial ownership filing. However, 1 October is the start of the new rules, not a universal filing deadline, and the register will not be publicly searchable.
The practical questions are: who must be reported, which deadline applies to your company, and who will submit the information?
Can Alpine Capital explain the requirements and register the information for me?
Yes. Alpine Capital helps international owners of Swiss AGs and GmbHs understand their obligations, prepare the required information and submit the company’s beneficial ownership report.
We review your ownership structure, establish the applicable deadline and explain which personal details and supporting documents are needed. With a power of attorney from your company and the necessary EasyGov authorisation, we can handle the filing on its behalf and provide the registration confirmation.
Our standard service is CHF 250 plus VAT for qualifying existing clients and CHF 390 plus VAT for qualifying new clients. Each package covers one company and up to three direct beneficial owners in a straightforward structure. Holdings, multi-level ownership and other complex arrangements are quoted individually.
The full scope and limits are explained below.
Contact team@alpinecapital.ch with your company name and a brief description of its ownership structure.
Official guidance on filing through an authorised representative
I am a foreign owner of a Swiss AG or GmbH. Do the rules apply to me?
Yes. A privately owned Swiss AG or GmbH generally falls within the reporting rules regardless of its owners’ nationality or country of residence.
Living outside Switzerland does not create an exemption. Neither does having a company with no employees, little activity or no turnover.
The company submits the report. Owners must provide the information and documents needed to establish who ultimately owns or controls it.
Specific exemptions exist, including for listed companies and qualifying subsidiaries. These are not general exemptions for foreign investors.
This article focuses on companies incorporated under Swiss law. Foreign-incorporated entities with a Swiss branch, Swiss management or Swiss property require a separate assessment.
Will my name and personal details become public?
No. The Swiss Transparency Register, also called TranspaReg, is not a public shareholder database.
Access is restricted to legally authorised authorities, financial intermediaries and certain advisers for permitted purposes. Competitors, customers and members of the public cannot simply browse the register.
However, confidential does not mean anonymous to banks or authorities.
The existing Commercial Register remains separate. Information already publicly recorded there, such as your position as a director or GmbH shareholder, does not become private because of the new register.
What is my company’s filing deadline?
For a company already registered before 1 October 2026, the answer depends on its existing Commercial Register entries, legal form, audit status and subsequent register amendments.
First check whether all actual beneficial owners are already entered in the Commercial Register as shareholders or members of a company governing body. This can make a substantial difference to the transition period.
I own 100% of an AG and am also registered as a board member
If you are the sole beneficial owner and are already registered as a board member, the company can qualify for the two-year transitional period.
For filing planning, use 30 September 2028 as the cut-off, unless an earlier Commercial Register amendment triggers an earlier deadline.
An additional Swiss board member does not, by itself, remove this transition period. The relevant question is whether all actual beneficial owners are already registered in a qualifying capacity.
I own an AG, but only my Swiss director appears in the Commercial Register
Your director’s entry is not an entry of you as the beneficial owner.
Where the two-year rule does not apply, the standard filing cut-offs are:
- AG subject to an ordinary, or full, audit: 31 December 2026 — a three-month transition.
- AG not subject to an ordinary audit, including an AG with a limited audit or valid audit opt-out: 28 February 2027 — a five-month transition.
An earlier Commercial Register amendment can bring the filing obligation forward.
I own a GmbH
If all actual beneficial owners are already personally registered as shareholders or governing-body members, the two-year transition can apply, subject to the earlier-amendment rule.
A holding company appearing as the registered shareholder is not the same as its ultimate individual owner appearing in the register.
Where the two-year rule does not apply, the standard categories include:
- GmbH subject to an ordinary audit: 31 January 2027 — a four-month transition.
- GmbH with a valid audit opt-out falling within the six-month category: 31 March 2027.
For a GmbH with a limited audit that does not qualify for the two-year period, the classification under Article 51 should be confirmed individually. Do not automatically apply the AG deadline or assume that every GmbH has the same deadline.
The dates above are filing-planning cut-offs for the statutory transition periods. Confirm your company’s category before relying on a date.
Legal basis: Article 51 of the Transparency Act
Can a change of director or registered address shorten my deadline?
Yes. The first amendment of an existing company’s Commercial Register entry after the law takes effect triggers a filing period of one month.
This is not limited to an ownership change. A director change or registered-address amendment can also matter.
A company otherwise entitled to the two-year transition may therefore need to file much earlier. Always use the earlier applicable deadline; an amendment does not extend a deadline that expires sooner.
Federal Office of Justice guidance on transitional periods and register amendments
What happens if I establish a new company from 1 October 2026?
The longer transition periods for existing companies do not apply to a new incorporation.
A newly registered Swiss company must report within one month of its Commercial Register entry, calculated by reference to publication in the Swiss Official Gazette of Commerce, known as SHAB.
Include the Transparency Register filing in the incorporation process rather than leaving it until the first annual accounts or tax return.
Who must be reported: me, my holding company or my Swiss director?
The register identifies natural persons: the individuals who ultimately control the company.
Direct ownership of at least 25% of the capital or voting rights is a key threshold. Indirect ownership, joint control and control exercised through contractual rights can also matter.
For example:
- Two individuals each directly owning 50% normally both qualify.
- If you own 100% of a holding company that owns 100% of the Swiss company, the ownership analysis leads to you, not just to the holding company.
- A nominee shareholder or local director does not replace disclosure of the actual beneficial owner.
Owning less than 25% does not automatically exclude someone. Voting arrangements or other control rights can still bring that person within the rules.
The analysis must follow the actual ownership and control structure, not merely the names on the first page of a company extract.
What information and documents will I need?
Prepare each beneficial owner’s full name, date of birth, nationalities, residential municipality, postcode and country, together with information about the nature and extent of their control.
Supporting documents may include the share register, ownership chart and relevant shareholder or voting agreements.
A Swiss AHV social security number is not a prerequisite for a foreign beneficial owner. Where no AHV number exists, identification can use an accepted document, including a foreign passport or identity card.
Alpine Capital will explain which documents are required for your structure.
Legal basis: identification and reporting requirements under the Transparency Ordinance
Can I file myself through EasyGov?
Yes. A company can arrange its own filing through an appropriately authorised person or appoint an external representative.
Creating an EasyGov account is only the access step. It does not mean the beneficial ownership report has been submitted.
When Alpine Capital handles the filing, the authority to act must come from the company. Being a shareholder does not automatically mean you can sign the company’s power of attorney; its signing rules must be respected.
The necessary EasyGov access must also be established for that company.
Regular reporting starts on 1 October 2026. Voluntary early reporting is available under the pilot arrangements, subject to their conditions. Preparation and authorisation can therefore begin before the regular launch.
As at September 2026, the alternative filing route through cantonal Commercial Register offices is not yet operational.
Official guidance on filing through EasyGov
Official information on early reporting and the pilot arrangements
My name is already in the Commercial Register. Is registration automatic?
Do not assume so. Existing entries can support simplified reporting where the conditions are met, but the company should still verify that its filing has been completed.
The simplified procedure and the two-year transition are different tests.
For the simplified one-person AG procedure, the sole individual shareholder must also be the sole registered board member and sole beneficial owner, with further conditions applying.
An additional Swiss director can therefore prevent that simplified procedure without necessarily removing the two-year transition.
My bank already has my beneficial ownership declaration. Is that enough?
No. Bank due diligence and the company’s Transparency Register filing are separate obligations.
The bank holding your passport or ownership declaration does not mean your company has filed. Equally, a register entry does not replace the bank’s own checks.
Legal basis: the register and financial intermediaries’ obligations
How much does Alpine Capital charge?
Our fees depend on the complexity of the ownership structure, the number of beneficial owners and the work needed to obtain and review the information.
Foreign nationality or residence abroad does not, by itself, move a straightforward case into the complex-structure category.
Existing clients: CHF 250 plus VAT
For existing Alpine Capital clients whose relevant company and ownership documentation is already available and requires only a standard update.
The package covers one Swiss AG or GmbH, one initial filing and up to three directly participating beneficial owners who are natural persons, within a straightforward ownership and control structure.
New clients: CHF 390 plus VAT
For new clients with one Swiss AG or GmbH and up to three directly participating beneficial owners who are natural persons, within a straightforward ownership and control structure.
The package includes initial document collection support and review, together with the preparation and filing service.
A sole individual owner living abroad can qualify for this package. An intermediate holding company is not a simple direct-ownership case.
What is included in both standard packages?
- Review of the company’s reporting position, applicable deadline and straightforward ownership structure.
- Identification of the required information and review of the documents supplied.
- Preparation of the company power of attorney and coordination of the required EasyGov authorisation.
- Preparation and submission of one initial beneficial ownership report.
- Delivery of the registration confirmation once issued.
You provide complete and accurate ownership information and the requested documents. Your company’s statutory reporting responsibilities remain in place even when the submission is delegated.
Holdings and complex structures: individual quotation
An individual quotation applies to holding structures, ownership through intermediate companies, multi-level international groups and other arrangements requiring additional analysis.
This also includes more than three reportable beneficial owners, trusts, nominee or fiduciary arrangements, unusual voting or control rights, and incomplete or inconsistent ownership documentation.
Even a structure with only one ultimate beneficial owner may require an individual quotation if ownership passes through several entities.
The three-person limit is a package limit, not a legal reporting limit. Every reportable beneficial owner must be declared.
We confirm whether a standard package applies after reviewing the structure. Additional work is quoted and agreed before proceeding.
What is not included in the initial filing fee?
Subsequent changes, ongoing monitoring, additional companies, restructuring, specialist legal opinions, translations, notarisation, external document-retrieval costs and representation in enforcement proceedings are outside the standard package unless expressly agreed.
The quoted prices are one-time professional service fees per company, excluding VAT.
The official register itself does not charge for the initial entry, updates or deletion. Alpine Capital’s fee covers professional review, preparation and submission; it is not a government registration charge.
Do I need to file again every year?
The system is based on an initial filing followed by updates to reportable information, rather than a general annual re-registration.
Changes to reported facts must generally be notified within one month after the company becomes aware of them. This can include a change in beneficial ownership, relevant control rights or reported personal details.
Agree who will monitor changes and arrange updates. Ongoing monitoring and subsequent filings are separate from Alpine Capital’s initial filing package.
What happens if I do not file?
Intentional breaches of the reporting and information duties can attract fines of up to CHF 500,000.
This is not an automatic charge for every late filing. However, the company should not ignore the obligation or assume that an adviser, bank or director has completed it without confirmation.
What should I do now?
Establish your company’s deadline, identify who will submit the report and prepare the ownership information and identification documents.
To arrange assistance, email team@alpinecapital.ch with your company name, whether it is an AG or GmbH, and whether you own it directly or through other entities.
Alpine Capital will explain the requirements, confirm the applicable service fee and coordinate the authorisation and filing.
Information checked as at 16 September 2026. This article provides general information, not a company-specific legal opinion. Reporting requirements and deadlines depend on the company’s actual circumstances.