On 1 October 2026, the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners — the LTPM — entered into force. It creates something Switzerland has never had: a central federal register of beneficial owners, held by the Federal Office of Justice and filed electronically through EasyGov. Roughly 600,000 Swiss entities fall within its scope.
For compliance teams at banks and External Asset Managers, the temptation is to read this as one more filing obligation that lands on clients rather than on the institution. That reading is wrong in an instructive way. The register changes where beneficial ownership information lives, who is accountable for its accuracy, and what a financial intermediary can be expected to corroborate. It does not, however, transfer your due diligence duty to the Federal Office of Justice — and the gap between those two statements is where the operational work sits.
This article sets out what the LTPM requires, what the transitional deadlines actually mean for the next twelve months, and what changes in a client lifecycle that already collects UBO data today.
1. What changed on 1 October 2026
Before the LTPM, beneficial ownership information in Switzerland rested on two pillars. Companies maintained their own lists of shareholders and beneficial owners at their registered office. And financial intermediaries subject to the Anti-Money Laundering Act identified beneficial owners as part of their own due diligence, typically by collecting a Form A or equivalent declaration.
That architecture had a structural weakness that every compliance officer will recognise: the two pillars were never reconciled. The company's internal list and the bank's file could diverge for years without anything surfacing the discrepancy. Nobody held the authoritative version, because there was no authoritative version to hold.
The LTPM introduces one. Legal entities in scope must now identify their beneficial owners, verify their identity with reasonable diligence, document that verification, and report the result to the federal register. Supporting documents must be retained for ten years. The register is administered by the Federal Office of Justice and filed through EasyGov, the Confederation's electronic one-stop portal.
The verification requirement is the part most easily skimmed over. Identifying a beneficial owner is not the same as verifying them. Under the LTPM, a company cannot simply record what a shareholder asserts: it must take reasonable steps to confirm that the person named is in fact the person behind the holding, and keep the evidence.
2. Who must file
The scope is broad but not universal. Entities in scope include:
- Public limited companies (SA/AG)
- Limited liability companies (Sàrl/GmbH)
- Cooperatives
- SICAVs, SICAFs and limited partnerships for collective investment schemes
- Foreign legal entities with a Swiss branch, Swiss effective management, or Swiss real estate
Entities outside the scope include foundations, associations, sole proprietorships, and entities that are at least 75% publicly owned.
Two points deserve emphasis for cross-border practitioners. First, a foreign entity does not escape the obligation merely by being foreign: Swiss effective management or Swiss real estate is enough to bring it in. Structures that hold a Swiss property through an offshore vehicle are squarely in scope. Second, the exclusion of foundations and associations is a scope decision, not a statement that their beneficial ownership is uninteresting — your own due diligence on a foundation remains exactly as demanding as it was, and now without a register to corroborate it. For those structures, see our guide to KYC for trusts, foundations and complex structures.
3. Who counts as a beneficial owner
The core threshold will be familiar to anyone who has worked with the EU's AML directives or the FATF standards. Under Art. 2 LTPM, a beneficial owner is a natural person who holds, directly or indirectly, alone or in concert with third parties, at least 25% of the capital or voting rights.
Two refinements matter in practice.
Indirect holdings. The implementing ordinance (Art. 2(2) OTPM) treats a person as a beneficial owner through an intermediate entity where they control more than 50% of the capital or voting rights of that intermediate entity, and the intermediate entity holds at least 25% of the target. This is a chain test, and it is where multi-layer structures generate most of their analytical work.
Control by other means. Art. 3 OTPM extends beneficial ownership beyond the arithmetic of shareholdings to persons exercising control through rights to appoint or dismiss management, veto powers, decisions on profit distribution, or authority over asset disposal. Those rights may arise from articles of association, shareholders' agreements, options, convertible loans or related-party relationships.
That second limb is the one that will not be solved by a spreadsheet. A shareholders' agreement granting a minority holder a veto over the sale of the principal asset creates a beneficial owner who appears nowhere in the capital table. Identifying those persons requires reading the constitutional documents — which is precisely the work that automating UBO verification is meant to make tractable rather than eliminate.
4. The transitional deadlines are the near-term pressure
The register did not open with a two-year grace period applying evenly to everyone. The transitional regime is staged, and the staging is what creates work in the coming months.
Deadlines range from three months for companies subject to ordinary audit, through intermediate periods of three to six months depending on entity type, to two years for entities whose beneficial owners are already recorded in the Commercial Register. Foreign entities in scope have until 1 May 2027. Separately, any change must be filed within one month of the corresponding change in the Commercial Register.
For a bank or EAM, the practical consequence is a sequencing problem rather than a legal one. Your client base will not become filed all at once. For the next eighteen months you will be dealing with a population in which some clients have filed, some are inside a transitional window, and some — foundations, associations, certain foreign entities — will never file at all. Any process that assumes "check the register" as a uniform step will break on the second case.
5. The register is not public — and that is the point
The LTPM register is not a public transparency instrument in the way the EU's registers were conceived before the Court of Justice's 2022 ruling. Access is limited to competent authorities and, subject to the statutory conditions, to financial intermediaries and advisers subject to the Anti-Money Laundering Act, to the extent access is necessary to perform their due diligence obligations.
This is a meaningful design choice and it has two consequences worth stating plainly.
The first is favourable: as a regulated intermediary, you gain a corroboration source that did not previously exist. Where a client declares a beneficial ownership structure, you can now compare that declaration against what the entity itself has filed under penalty of law. Divergence between the two is a signal — and a documented, dated, externally sourced one.
The second is a constraint that compliance functions should internalise early. Access is tied to necessity for your due diligence. It is not a general research facility, and querying it outside that purpose is not a neutral act. Institutions should expect to justify, and therefore to log, the business reason for each consultation. If your CLM platform cannot record why a register lookup was performed and against which client file, that justification will have to be reconstructed manually at audit time — which is the expensive way to do it.
6. What the LTPM does not change
This is the section to read twice, because the most costly misreading of a register is that it discharges a duty.
Your AML due diligence obligation is unchanged. The LTPM places duties on legal entities. It does not amend your obligation under the Anti-Money Laundering Act to identify the beneficial owner of your counterparty, to understand the purpose and background of the relationship, or to monitor it on a risk basis. A register entry is evidence. It is not a conclusion.
The register is not a verification service. The entity verifies and files; the Federal Office of Justice maintains the register. The register does not validate the substance of what was filed. An incorrect filing produces an incorrect entry, and the sanction — fines of up to CHF 500,000 under Art. 43 LTPM — falls on the filer, not on the intermediary who relied on it. Relying on a register entry as if it were an independently verified fact is the same category of error as relying on a client's own Form A without corroboration.
Risk assessment still drives the work. Nothing in the LTPM changes customer risk scoring or the intensity of due diligence that follows from it. A high-risk structure with a clean register entry remains a high-risk structure.
The sensible mental model is the one the FATF has long used for registers: they are one of several sources, best used in combination with information obtained from the client and from independent sources. The register's real contribution is not that it answers the question — it is that it gives you a second, legally accountable answer to compare against the first.
7. What changes operationally
Four things change in a well-run client file.
A new corroboration step at onboarding. For in-scope entities, the register becomes a check alongside the Commercial Register extract, the client's own declaration and the constitutional documents. The valuable output is not the entry itself but the comparison.
Discrepancy handling becomes a defined process. This is new work, and it is the part institutions most often underestimate. When a client's declared structure differs from the filed structure, somebody must decide whether the cause is a stale filing, a transitional window not yet elapsed, a genuine change in control, or a misrepresentation. Those four causes call for four different responses, and only one of them is a simple file update. The process needs an owner, a timeline and an audit trail.
Periodic reviews gain a trigger. A change filed to the register is a change in beneficial ownership, which is a material event in the relationship. Institutions still running calendar-driven reviews will learn of it at the next scheduled review — up to three years late. Institutions running perpetual KYC treat it as what it is: an event that re-opens the file when it happens. The LTPM is, in that sense, one more argument against the fixed-interval model, which we examined in how to choose periodic review software.
Record-keeping extends. The ten-year retention imposed on filers has an echo on your side: if you rely on a register consultation as part of your due diligence, the evidence of that consultation — what was checked, when, by whom, and what it returned — needs to survive as long as the relationship and its retention period.
8. What to do in the next ninety days
A short, honest list.
- Segment the client base by LTPM status. In scope and filed; in scope and within a transitional window; out of scope entirely. The third group is larger than people expect and needs an explicit decision, not an exception queue.
- Identify the short-deadline population first. Entities subject to ordinary audit had three months. Those files should already be reconcilable.
- Decide the discrepancy policy before the first discrepancy. Who investigates, within what timeframe, what escalates, and what is documented. Writing this after the first case means writing it under pressure.
- Instrument the register lookup. Log the purpose, the client file and the result. If this is manual, it will be inconsistent, and inconsistency is what audits find.
- Review client communications. Many clients will receive their first LTPM filing obligation without understanding it, and will ask their bank or EAM what to do. A prepared, accurate answer is a relationship asset; an improvised one is a liability.
- Check the foreign-entity population against the 1 May 2027 deadline. Swiss real estate held through a foreign vehicle is the pattern most likely to be missed.
9. Where a CLM platform helps
The LTPM does not create a new category of compliance work so much as it raises the cost of fragmented work. Every one of the operational changes above assumes a single client record: one place where the declared structure, the filed structure, the supporting documents, the lookup history and the review trigger coexist. Where those live in four systems, the reconciliation is manual, and the manual version does not scale across a book of several thousand entities.
Wecan's client lifecycle management platform is built around that single record. Beneficial ownership is held as a structured graph rather than a document, so a change in control is a change to the record — not a new PDF filed alongside the old one. Review triggers fire on events rather than on dates. And the audit trail is a by-product of doing the work, not a report assembled afterwards.
The Swiss transparency register is, on balance, good news for institutions that already treat beneficial ownership as living data. It gives them a second source to reconcile against. For institutions that treat it as a document collected at onboarding and revisited every three years, it mostly creates a new way to be demonstrably out of date.
This article is provided for information purposes and does not constitute legal advice. The LTPM and its implementing ordinance should be read in their authoritative versions, and institution-specific questions addressed with qualified counsel.
