Switzerland introduces a new beneficial ownership transparency regime affecting companies and private trusts, requiring clearer control documentation and compliance readiness.

1. Background

On 26 September 2025, the Swiss Federal Parliament approved the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (the “Transparency Act”). The Act is expected to come into force in 2027 and represents the most significant shift in Switzerland’s beneficial ownership compliance regime since the implementation of FATF standards in 2015. The purpose of the Act is to strengthen the traceability of ownership and control in corporate and trust structures, enhance anti-money laundering safeguards, and align Switzerland with international expectations—while attempting to preserve the country’s long-standing tradition of financial and structural privacy.

2. Key Structural Changes (Simplified Version)

The Transparency Act introduces significant changes for Swiss legal entities, certain foreign entities, and trusts managed in Switzerland. These entities must identify the individuals who ultimately control them and collect key details such as name, date of birth, nationality, residential address, and the nature of control. Swiss companies will be required to submit this information to a new government-operated transparency register. Trustees, however, will only need to maintain and update internal records rather than report directly to the register.

Changes in beneficial ownership or control must be reported or recorded within one month. The transparency register will not be publicly accessible; only designated Swiss authorities and financial intermediaries subject to anti-money laundering obligations may access it for due diligence purposes. Intentional non-compliance can lead to criminal fines of up to CHF 500,000, and responsibility may fall on directors, shareholders, beneficial owners, or trustees depending on the circumstances.

3. Implications for Trusts and Trustees

The Act does not require trustees to submit beneficial ownership information to the transparency register. However, trustees must identify all beneficial owners and controlling parties, verify and document these identities, and ensure that such records remain complete and up-to-date. Trustees must also be prepared to disclose the information to competent Swiss authorities and regulated financial intermediaries in the context of due-diligence obligations under the Swiss Anti-Money Laundering Act. The Act therefore maintains the privacy of private trusts while imposing more formalized record-keeping and verification duties.

4. Cross-Border and Foreign Structures with Swiss Nexus

Where the place of effective management of a legal or trust structure is located in Switzerland, the Transparency Act requires a Swiss representative to be designated and for beneficial ownership records to be maintained in Switzerland. This will affect numerous existing family wealth structures involving holding companies in Hong Kong or Singapore and trust entities in jurisdictions such as the Cayman Islands, the British Virgin Islands, and Jersey, particularly where those structures rely on Swiss trust administration, advisory, or family office infrastructure.

5. Practical Considerations for High-Net-Worth Families (Simplified Version)

High-net-worth families and family offices should review trust documents and related records to ensure that beneficial rights and control relationships are clearly expressed. Where the structure relies on nominee arrangements or layered holding chains, it may be necessary to transition to a transparent and legally documented control framework that can be demonstrated through supporting documentation. Trustees and family offices should also implement internal compliance procedures to ensure beneficial ownership records are updated in a timely manner and can be promptly provided during regulatory or due-diligence reviews.

Conclusion

Switzerland is not abandoning its tradition of financial and structural privacy. Instead, it is moving toward a model of traceability without public exposure, where beneficial ownership information must exist, be accurate, and be verifiable, but is not openly disclosed. The Transparency Act will have lasting implications for private trusts, cross-border wealth planning, and multinational holding structures. Families and trustees should review their arrangements now to ensure they will remain compliant under the new regulatory expectations when the Act takes effect.