Since 1 October 2026, Swiss companies have been required to report their beneficial owners to the transparency register. This article explains the respective roles of the board of directors, fiduciaries and software. A cost example for a company limited by shares with several shareholders compares the different approaches. It also explains why collecting and updating information accounts for most of the work.
Since 1 October 2026, companies limited by shares, limited liability companies, cooperatives and other companies governed by Swiss law have been required to identify and verify their beneficial owners, document their findings and report them to the transparency register. This raises a very practical question for boards of directors and management teams: should the company handle the reporting itself, engage a fiduciary service provider or use specialised software?
The answer depends on the amount of work involved, which is often underestimated. In straightforward cases with just a few shareholders, all of whom are natural persons, a company can readily handle the reporting itself. As the number of people grows, the work involved in requesting, recording, checking and updating information increases noticeably, and a fiduciary can take on these tasks. The more time-consuming and complex the case, the more valuable it becomes to combine a fiduciary's services with software. This applies not only to complex structures, foundations or trusts, but also when information must be requested from several natural persons and kept up to date. The fiduciary handles the work, the software provides structure and traceability, and the board of directors retains a clear overview at all times.
This article explains who takes on which role, compares the costs of the different approaches using a practical example and shows how the company, its fiduciary and the software work together on the initial report and subsequent changes.
Table of Contents
- What needs to be done when reporting beneficial owners
- Who takes on which role
- Do it yourself, hire a fiduciary or use software: the options at a glance
- Cost example for a company limited by shares with several shareholders
- How the company, fiduciary and software work together
- Keeping track of changes
- Conclusion
- Next steps
What needs to be done when reporting beneficial owners
When people think about reporting to the transparency register, they usually picture a form on EasyGov. But most of the work happens before the report is submitted. The company must identify its beneficial owners, verify them with the required due diligence and document the outcome (Arts. 7 and 8 LETA). The documentation must record not only the result, but also what was examined and why a particular person was or was not reported. If an investigation proves inconclusive, the steps taken must also be documented (Art. 8 para. 2 LETA). All criteria must be assessed alongside one another: a holding of at least 25% of the capital or voting rights, individually or acting in concert, directly or indirectly, as well as any form of control by other means. Anyone who meets even one of these criteria is a beneficial owner (Art. 4 para. 1 LETA and Arts. 1–4 LETO). Where control is exercised through intermediary companies, foundations or trusts, the company must trace the chain of control back to the natural persons who ultimately control it (Arts. 2, 7 and 15 LETO). After the initial report, any change to a registered fact must be reported within one month (Art. 10 LETA).
Two points are crucial when allocating tasks. First, responsibility for reporting remains with the highest-ranking member of the governing body, even if the task is delegated to a fiduciary (Art. 12 para. 2 LETA). A fiduciary can take work off the company's hands, but not its responsibility. Second, the company does not have to gather all the information on its own: shareholders with a controlling interest and the beneficial owners themselves are required to provide the necessary information and supporting documents (Arts. 13 and 14 LETA). These duties to cooperate provide the basis for efficient collaboration between the company, fiduciary and software.
Who takes on which role
Efficient reporting to the transparency register relies on a clear division of responsibilities. Each participant contributes something different, and costs remain low when each handles the tasks they are best placed to perform.
The board of directors retains oversight and responsibility
The board of directors or management does not have to enter the report itself, but remains responsible for ensuring that it is accurate and submitted on time (Art. 12 para. 2 LETA). Above all, the board needs assurance. It wants to know that all shareholders have been contacted, that the information is complete and that, even two years later, it will still be possible to understand exactly why those particular individuals were reported. This assurance does not come from another Excel spreadsheet, but from a properly documented process that the board can review at any time.
The fiduciary collects information, records it and submits the report
Most of the work lies in obtaining and managing information. Shareholders must be contacted and reminded to provide missing details. For each beneficial owner, the name, date of birth, nationality and place of residence must be obtained. It must also be established whether the beneficial owner has a Swiss social security number (AHV number); if not, a copy of an identity document must be requested (Art. 10 LETO). The information must then be recorded, checked for completeness and filed.
A fiduciary is well placed to perform this work on behalf of the company. Moreover, many fiduciaries are already registered on EasyGov for their clients and have access to the platform. It therefore makes sense for the fiduciary to prepare and submit the actual report as well. If the fiduciary undertakes these tasks under a mandate from the company, it owes the company due care in carrying out the mandate and must be able to account for its activities (Art. 398 para. 2 and Art. 400 para. 1 of the Swiss Code of Obligations). In its own interest, the fiduciary should therefore keep a traceable record of how it proceeded.
Software provides structure and traceability
Software does not replace the fiduciary, but it makes the fiduciary's work more efficient and scalable, while ensuring that the result can be traced at any time. Shareholders can enter their details themselves rather than sending them by email. The fiduciary can see at a glance what is still missing and is guided through the statutory questions, even where complex structures involve multi-level chains of control or shareholders organised as trusts, contractual investment funds or foundations.
The result is a dossier showing who was reported, who was deliberately excluded from the report and, most importantly, why. The dossier helps the company meet its statutory documentation obligation and provides the fiduciary with evidence that the investigation was carried out diligently. The fiduciary can use the software largely independently within the scope of the mandate, while the board of directors can check the status at any time without having to ask for an update.
Do it yourself, hire a fiduciary or use software: the options at a glance
In practice, there are four ways to divide the work. The right choice depends on how many people need to be contacted, recorded and kept up to date, and how complex the ownership structure is. The more demanding the case, the greater the fiduciary's involvement and the more worthwhile software becomes.
| Option | Who does what | Suitable for | Points to consider |
|---|---|---|---|
| Company handles everything itself | The company requests and records information, documents its findings and submits the report. | Simple cases with a few shareholders, all natural persons. | Manageable internally, but the knowledge is concentrated in one person at the company. |
| Fiduciary handles everything manually | The fiduciary contacts people, collects information by email, maintains lists, assesses the situation and reports through EasyGov. | Companies with limited internal capacity and a manageable number of people. | Every follow-up question and subsequent change creates additional manual work. |
| Company and fiduciary share the work | The company provides an overview; the fiduciary supplements and checks the information and submits the report. | Smaller shareholder bases with a well-maintained share register. | The information is spread across lists and emails; changes have to be updated separately. |
| Fiduciary and software work together | Shareholders enter their own details; the fiduciary uses the software, checks information, reports and handles updates. | More demanding cases with several shareholders, holding companies, foundations or frequent changes. | Every step is documented, and subsequent changes build on the existing records. |
Costs deserve a closer look. Registration in the transparency register is free of charge; fees arise only if the authorities have to issue reminders or formal requests (Art. 41 paras. 1 and 2 LETA). Costs therefore mainly consist of time: the company's own time, the fiduciary's time and, where applicable, the cost of software. The key is how that time is spent. Every hour a fiduciary spends chasing information by email or reconciling different lists costs just as much as any other hour charged under the mandate.
Cost example for a company limited by shares with several shareholders
A simple example shows how the different approaches affect costs. A company limited by shares has around 20 shareholders, all of whom are natural persons. There are no agreements between them and no special rights. The fiduciary charges CHF 180 per hour. As a fiduciary will typically handle the work where there are several shareholders, the example compares the options involving a fiduciary. The figures are indicative estimates for the initial report.
| Option | Work involved | Cost (example) | Result |
|---|---|---|---|
| Fiduciary handles everything manually | 4–8 hours of fiduciary time | Approx. CHF 720–1,440 | Report completed; documents scattered across emails and lists |
| Company and fiduciary share the work | 1–2 internal hours plus 2–4 hours of fiduciary time | Approx. CHF 360–720 plus internal time | Report completed; documents scattered across emails and lists |
| Fiduciary and software work together | Guided entry by shareholders; 1–2 hours of fiduciary time for checks, reporting and follow-up queries | Software from CHF 89 plus fiduciary time | Report and complete dossier, available for review at any time |
At first glance, the options do not differ greatly for the initial report. The real difference lies in three factors that do not appear in an hourly estimate. First, when several people are involved, it is rare for all information to be complete from the outset. Follow-up questions, reminders and missing copies of identity documents can quickly increase the workload. Second, the work recurs with every share transfer, capital increase and change of residence of a reported person, because the information must be checked again and, where necessary, updated in the register. Third, without structured records, knowledge depends on a single individual. If the fiduciary or the person responsible within the company changes, the search starts all over again.
If a founder's foundation, a trust or a holding company also holds a substantial stake, the workload increases further. The participating legal entity cannot itself be a beneficial owner, as only natural persons qualify. The people behind it who must be reported as beneficial owners have to be identified through the chain of control, with special rules applying to foundations, associations and trusts (Arts. 2 and 5–8 LETO). In some cases, information about the legal entities in the chain of control must also be reported.
How the company, fiduciary and software work together
When a fiduciary uses software, reporting to the transparency register follows a clear process. The board of directors only needs to take action at two points: granting the power of attorney and approving the report.
- The company appoints the fiduciary and grants a power of attorney for EasyGov (Art. 27 LETO).
- The fiduciary transfers the information from the share register into the software and invites shareholders to enter their details themselves.
- The fiduciary checks the information for completeness and follows up on missing supporting documents.
- The software guides the fiduciary through the statutory criteria in sequence, from direct and indirect ownership through acting in concert to control by other means. For each criterion, the fiduciary is guided in determining whether it is met in the specific case and which of the recorded individuals may consequently qualify as beneficial owners.
- This produces a dossier documenting who the beneficial owners are and why.
- The board of directors reviews the result and approves the report.
- The fiduciary submits the report through EasyGov and keeps subsequent changes up to date.
What Konsento's Transparency Register Reporting Assistant contributes
Konsento is a Swiss LegalTech platform for the digital corporate governance of unlisted companies. Konsento's Transparency Register Reporting Assistant is designed precisely for this collaboration. For the fiduciary, it means fewer emails and fewer lists: shareholders enter their own details, and the fiduciary can see what is still outstanding at any time. Because the assistant guides users through the statutory questions, the fiduciary can manage even larger shareholder bases largely independently within the scope of the mandate and apply the same process to all clients.
For the board of directors, the assistant primarily provides assurance. You can see later exactly why one person was reported and another was not. If the bank, auditor or supervisory authority asks questions, the dossier, including a graphic showing the ownership structure, is readily available. A pre-filled Form K can also be generated for the bank if required. If the fiduciary or a member of the board changes, the knowledge remains with the company. When the shareholder base changes, the process does not have to start from scratch; it builds on the existing records.
Keeping track of changes
The work does not end with the initial report. Every change to a fact entered in the transparency register must be reported within one month after the company becomes aware of it (Art. 10 LETA). A change in shareholdings, however, is reportable only if it causes one of the 25%, 50% or 75% thresholds to be crossed in either direction (Art. 39 para. 3 LETO). In practice, the following events are particularly likely to trigger a review:
- Share sales, gifts and inheritances.
- Capital increases and new investors.
- New or amended agreements between shareholders.
- A change of residence or new nationality of a reported person.
The one-month period begins when the company learns of the change. If the fiduciary only finds out during the annual accounts process, the deadline may already have passed. If the share register is maintained digitally and linked to beneficial-owner information, every recorded share transfer can immediately trigger a review, allowing the fiduciary to prepare the change report using existing records. As the documents must also be retained for ten years (Art. 8 para. 3 LETA), a complete audit trail is not just a convenience feature but part of the legal obligation.
Conclusion
The question of whether a company should report to the transparency register itself, use a fiduciary or rely on software cannot be answered as an either-or choice. Entering information on EasyGov is the smallest part of the task. The real work lies in requesting, recording, checking and updating information, and it grows with each additional person, each additional layer of ownership and every change. In straightforward cases with just a few shareholders, all of whom are natural persons, the company can readily handle the report itself. Where there are several people, a fiduciary can take on the work. The more time-consuming and complex the case, the more valuable the combination of fiduciary and software becomes. The board of directors retains responsibility, but also has a clear overview at all times and knows exactly why each item of information was reported.
Next steps
Start by establishing how many people you need to contact and who should record, check and update the information in your company. Discuss with your fiduciary whether they can take on the task and would like to use software for it. Our free communication generator helps you contact your shareholders. If you want to identify beneficial owners, document your findings and keep them up to date in a single workflow with your fiduciary, you can find all the information about Konsento's Transparency Register Reporting Assistant.