Transparency Register and AMLA Revision: New Rules for Companies and Advisers in Switzerland

With the new Transparency Act (TJPG) and the revision of the Anti-Money Laundering Act (AMLA), Switzerland is fundamentally modernising its regulatory framework. Adopted in September 2025, the reform aligns with international FATF standards and strengthens the transparency of legal structures. The new provisions affect both companies and advisory service providers and are expected to enter into force in mid-2026. It is therefore essential to address the upcoming obligations at an early stage.

The Transparency Act (TJPG)

For the first time, the TJPG introduces a central, non-public transparency register, which will be maintained by the Federal Office of Justice. The register will record the beneficial owners of legal structures domiciled in Switzerland. Its aim is to increase the traceability of ownership and control structures and to reduce the risk of misuse.

The law applies, among others, to:

• Swiss corporations limited by shares (AG), limited liability companies (GmbH) and cooperatives

• SICAVs, SICAFs and other collective investment vehicles

• foreign legal entities with administrative, branch or real estate connections to Switzerland

• trustees with their registered office in Switzerland or carrying out administrative activities in Switzerland

Listed companies and their majority-owned subsidiaries, as well as supervised pension institutions, are excluded.

Companies must report their beneficial owners within one month and update any changes within the prescribed time limits. A beneficial owner is defined as any person who holds at least 25% of the capital or voting rights, or who otherwise exercises control. If no such person can be identified, the highest governing body must be entered in the register.

Responsibility for ensuring data quality lies with a supervisory body within the Federal Department of Finance. Failure to submit reports, or late reporting, may result in fines of up to CHF 500,000. Access to the register will remain restricted to authorities, financial intermediaries and advisers, insofar as this is necessary for the fulfilment of their statutory obligations.

Expanded Due Diligence Obligations under the AMLA

With the revision of the AMLA, certain advisory activities will for the first time fall within the scope of anti-money laundering regulation. In doing so, the legislator is responding to the view that real estate and structuring transactions in particular involve increased risks.

The following activities will now be subject to AMLA obligations, among others:

• acquisition and sale of real estate

• formation, administration and sale of non-operating companies

• assistance with capital transactions involving such structures

• long-term domicile services

Excluded are traditional legal and notarial activities carried out in the context of proceedings, licensed audit firms, as well as certain transactions with a low-risk profile, such as intra-family asset transfers or real estate transactions below CHF 5 million, provided that the entire payment flow is processed through banks.

Advisers who fall within the scope of the new provisions will in future be required to identify clients and beneficial owners, document the purpose and background of transactions, assess risks, establish internal control mechanisms and join a self-regulatory organisation.

Impact on Companies and Advisers

The reform introduces expanded obligations in the areas of reporting, documentation and control. Companies must therefore review their structures, internal procedures and data processes and adapt them where necessary.

Advisers must assess whether their activities fall within the expanded scope of the AMLA and which organisational measures will be required. As key details will only be specified at ordinance level, it is advisable to closely monitor the further legislative process.

Next Steps

With the transparency register and the expanded due diligence obligations, Switzerland is setting new standards in anti-money laundering prevention. For companies and advisers, this means increased transparency requirements and additional organisational obligations. The key priority now is to take the necessary steps at an early stage.

Our Recommendation

Companies should promptly review their ownership and control structures, define internal processes for reporting and updates, and clearly allocate responsibilities. Advisers would be well advised to assess whether their services are relevant under the AMLA, adjust their internal controls and prepare in good time for membership in a self-regulatory organisation. A proactive approach will enable a smooth transition and reduce compliance risks once the new rules enter into force in 2026.

Joel Stampfli

KMU-Finanzexperte mit eidg. Diplom, Treuhänder

mit eidg. Fachausweis, Leiter Treuhand

+41 61 205 89 12 joel@adills.com