Strengthening Financial Integrity: Switzerland’s New Register of Beneficial Owners

Switzerland places great importance on the credibility of its financial centre. Accordingly, on 26 September 2025, the Swiss Parliament adopted the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (the ‘Legal Entities Transparency Act’; ’LETA’). This Act establishes a register of beneficial owners, enabling Switzerland to comply with the international standards of the Financial Action Task Force.

LETA is scheduled to enter into force in the second half of 2026 on a date to be set by the Federal Council, which is also expected to publish a draft ordinance implementing the Act before the end of 2026.

The aim of this article is to provide an overview of the key points of this new legislation.

The purpose of LETA is to combat effectively money laundering in the Swiss financial sector. The Act imposes on financial intermediaries an obligation to identify, verify, and report beneficial owners. This information will be consolidated in an electronic register maintained by the Federal Department of Justice and Police. The transparency register is intended to ensure that authorities have rapid and efficient access to information.

Upon taking effect, LETA will fully replace the current beneficial ownership identification framework contained in articles 697j et seq. of the Swiss Code of Obligations, which presently governs Swiss corporations (SA/AG) and limited liability companies (Sàrl/GmbH). The obligation for companies to keep an internal ’list of beneficial owners’, together with shareholders’ corresponding disclosure duties to the company, will be supplanted by LETA’s broader information-gathering, record-keeping, and disclosure requirements.

The scope of this new law encompasses the following entities:

• Swiss legal entities, including corporations (SA/AG), partnerships limited by shares (SCA/KommAG), limited liability companies (Sàrl/GmbH), cooperatives, investment companies with variable capital (SICAVs) or fixed capital (SICAFs), and limited partnerships for collective investments; and
• foreign legal entities with ties to Switzerland, specifically those that: maintain a registered branch in Switzerland, have their effective place of management in Switzerland or own or acquire Swiss real estate.

LETA will also apply to trustees who are domiciled in Switzerland or administer a trust from Switzerland, provided they are not already subject to the Anti‑Money Laundering Act. Although trustees are already required to verify the identity of beneficial owners and to identify directors, the new law additionally requires them to retain the information they collect internally. There is however no obligation to register this information in the transparency register.

State-owned companies and listed companies do not fall within the scope of LETA. Associations and foundations required to register in the commercial register, as well as lawyers and notaries, are not subject to LETA either.

Additionally, companies will be required to identify their beneficial owners and report that information to the transparency register. The information to be registered would include personal information (full name, date of birth, nationality and address) as well as information on their role within the entity, such as the type and the extent of their control on the entity. Companies will have to verify the information using appropriate means and report it to the transparency register.

After entering the commercial register, a company shall have one month to report the identity of the beneficial owners and the information requested. Changes to the recorded information must also be reported within one month of their occurrence.

A financial intermediary who detects an important discrepancy between the information in the transparency register and the one in its possession will be required to clarify it and if still unclear should report it to the supervisory authority.

The entries in the register are declarative in nature and do not have constitutive effect. However, the examination of beneficial owners by financial intermediaries remains governed by AMLA. If this examination is conducted with the due diligence required by the circumstances and no anomalies are detected, then financial intermediaries can rely on the entries in the register.

The violation of the obligation to notify the register and the provision of false information to the supervisory authority will be penalised in accordance with the provisions of Swiss administrative criminal law. The fine could be up to CHF 500,000. To be penalised, the violation must be intentional and not simply due to a negligence. This is a difference with the preliminary draft that planned to penalise negligence and that received a lot of criticism. The non-compliance by the financial intermediary of its obligation to report discrepancies is, however, not penalised under LETA.

Finally, access of the register is not public and is limited to specified authorities as detailed in the legislation, but financial intermediaries will also be granted access to the register to the extent necessary to fulfil their due diligence obligations. The supervisory authorities provided for by AMLA, as well as self-regulatory organisations and other authorities mentioned in the law, will have access to the data online. However, these authorities will only have access to deleted data in specific cases and upon a justified request.

Swiss law firm with an international reach (throughout his offices in the majority of the financial centres), Charles Russell Speechlys SA is specialised in providing Swiss legal advice to families, entrepreneurs and investors, with a strong expertise on cross-border matters.