Entry into Force of the Federal Act on the Transparency of Legal Entities: Transitional Periods and Practical Preparation for Reporting Obligations

Introduction

With the Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (ATLE), Switzerland is introducing a central transparency register. In the future, companies will be required to identify, document and report their beneficial owners to this register. For many corporations, the key questions already arise today: when will the Act enter into force, which transitional periods will apply, and how can companies prepare in an organisational and technical manner?

This article outlines the expected timeline, explains the reporting obligations towards the transparency register and shows why it is advisable not to postpone the necessary preparatory steps.

Table of Contents

• Entry into force of the Federal Act on the Transparency of Legal Entities: Current Status
• Start of the Reporting Obligation: The Relevant Point in Time
• Transitional Periods for Reporting Obligations
• Register of Beneficial Owners as an Existing Obligation
• Early Preparation as an Organisational Advantage
• Digital Support for Identifying Beneficial Ownership
• Forward Effect of Data Collected Today
• Conclusion

Entry into Force of the Federal Act on the Transparency of Legal Entities: Current Status

The entry into force of the Federal Act on the Transparency of Legal Entities will be determined by the Federal Council once the technical systems required to operate the transparency register are ready. According to the current state of knowledge, this is expected to be the case around mid-year, making an entry into force on 1 October 2026 likely. However, these timelines are not yet definitive and delays remain possible.

Upon entry into force, new obligations will apply to almost all legal entities registered in the commercial register. Listed companies, associations, foundations and sole proprietorships are excluded. These obligations apply regardless of whether the ownership structure is simple or complex.

Start of the Reporting Obligation: The Relevant Point in Time

As a rule, the reporting obligation under the Federal Act on the Transparency of Legal Entities begins with the entry into force of the Act itself. From that moment, legal entities must identify, document and report their beneficial owners to the transparency register within the statutory deadlines.

It is important to note that the reporting obligation does not require a request from the authorities. It arises automatically by operation of law upon entry into force.

In addition, the first change recorded in the commercial register after the entry into force of the Act may trigger the reporting deadline. In such cases, the reporting period begins with that change, regardless of whether the general transitional period has already expired.

Transitional Periods for Reporting Obligations

The Federal Act on the Transparency of Legal Entities does not provide for a single uniform transitional period. The applicable deadlines depend on the legal form, audit status and complexity of the ownership structure.

Legal entities whose beneficial owners are already fully identifiable from the commercial register benefit from a maximum transitional period of two years from the entry into force of the Act. This applies, for example, to limited liability companies, as all shareholders and managing directors are listed by name in the commercial register. The same may apply to corporations whose beneficial owners are all members of the board of directors and therefore already registered.

All other legal entities are subject to significantly shorter transitional periods. Depending on their structure and audit requirements, the transitional period amounts to:

• three months for corporations subject to ordinary audit
• four months for other entities subject to ordinary audit
• five months for corporations without ordinary audit
• six months for other companies and legal entities

For many moderately complex and complex structures, this means that the deadline will already expire between the end of 2026 and spring 2027.

Register of Beneficial Owners as an Existing Obligation

Under current Swiss company law, corporations are already required to maintain a register of beneficial owners. This register serves as internal documentation of the assessments made regarding beneficial ownership.

The Federal Act on the Transparency of Legal Entities strengthens this obligation by requiring the relevant documentation to be retained for ten years. Companies that have not yet systematically documented beneficial ownership are therefore strongly advised to establish such a register at an early stage.

Early Preparation as an Organisational Advantage

Companies that clarify and document their ownership structure today gain several advantages:

• Reporting to the transparency register can be completed without time pressure.
• Inquiries from authorities, banks or advisers can be answered efficiently.
• Internal compliance documentation is complete and audit-proof.

Early data collection also reduces the risk of errors and subsequent corrections after the Act enters into force.

Moreover, shareholders’ reporting obligations are deemed fulfilled if they have already complied with the existing reporting requirements under Swiss company law, provided that no relevant changes have occurred. This is an important prerequisite for timely reporting by the company itself.

Digital Support for Identifying Beneficial Ownership

Konsento already supports companies in the practical implementation of their legal obligations relating to beneficial ownership. Konsento’s free share register records a corporation’s ownership structure in a legally compliant and transparent manner. On this basis, beneficial owners can be systematically identified, documented and kept up to date.

Shareholders have direct access to the platform and can enter and manage their beneficial ownership information themselves. Companies can invite shareholders to provide or confirm the required information. All changes are documented in a structured and audit-proof manner.

This creates a complete and consistent data basis even before the entry into force of the Federal Act on the Transparency of Legal Entities, meeting both current and future requirements.

Forward Effect of Data Collected Today

Of particular practical relevance is the fact that beneficial ownership information collected today will be deemed to fulfil reporting obligations after the Act enters into force, provided that no relevant changes occur. Shareholders therefore do not need to re-report their beneficial ownership.

This significantly reduces administrative effort and increases legal certainty.

Conclusion

For most companies subject to the Transparency Act, the transitional periods for reporting to the transparency register are extremely short and require thorough preparation. Companies should therefore already begin today to systematically clarify their ownership structure and to identify and document their beneficial owners.

The Transparency Act builds on existing obligations and, in particular, extends the retention period for the relevant registers to ten years. A digital share register makes it possible to map the ownership structure in a legally compliant manner, to involve shareholders in the identification of beneficial ownership, and to centrally archive all relevant information.

Early data collection pays off, as information recorded before the entry into force of the Transparency Act is deemed to fulfil the reporting obligation, provided that no changes occur.

Those who act now avoid time pressure, reduce risks and create a solid foundation for future reporting obligations to the transparency register.

Register now on Konsento, set up a free share register, determine the beneficial ownership of the shares and create the register of beneficial owners.