Deadlines for the first report to the transparency register
The Federal Act on the Transparency of Legal Persons and the Identification of Beneficial Owners (TLPA) has been in force since 01.10.2026. The first report of beneficial owners to the transparency register is made on EasyGov, or under certain conditions through the commercial register (art. 11 TLPA), within a time limit that depends on the legal form and the audit regime (art. 51 TLPA).
Latest dates
| Company | Audit regime | Time limit | First report due by | Legal basis |
|---|---|---|---|---|
| Company limited by shares (AG / SA) | Ordinary audit | 3 months | 01.01.2027 | Three months: company limited by shares subject to ordinary audit (art. 51 para. 3 let. a) |
| GmbH / Sàrl, cooperative or other company | Ordinary audit | 4 months | 01.02.2027 | Four months: other company subject to ordinary audit (art. 51 para. 3 let. b) |
| Company limited by shares (AG / SA) | Limited audit, or waiver of the limited audit (opting out) | 5 months | 01.03.2027 | Five months: company limited by shares not subject to ordinary audit (art. 51 para. 3 let. c) |
| GmbH / Sàrl, cooperative, other company or legal person | Limited audit, or waiver of the limited audit (opting out) | 6 months | 01.04.2027 | Six months: other companies and legal persons (art. 51 para. 3 let. d) |
| Any legal form, when all beneficial owners are already entered in the commercial register as partners or officers | Any | 24 months | 01.10.2028 | Twenty-four months: all beneficial owners already entered in the commercial register as partners or officers (art. 51 para. 2) |
Earlier after a change in the commercial register
A change in the commercial register published in the SOGC since 01.10.2026 brings the deadline forward: the first report is due one month after that publication, if this is earlier than the date in the table (art. 51 para. 1). For example, after a change published on 16.10.2026 the report is due by 16.11.2026.
For a fiduciary
Each mandate has its own date. The legal form can be found in the commercial register, and any change to it in the Swiss Official Gazette of Commerce (SOGC). The audit regime is not published by the registers: it is confirmed with the company.
A third party reports on EasyGov for a company only once the company has authorised it, company by company: through the power-of-attorney letter that EasyGov posts to the registered office and the authorised signatories sign, or through an invitation from a person already authorised for the company (art. 27 OTPM).
Transparentia calculates this deadline for each mandate in a portfolio, with the same rules: see the demo.
Text of art. 51 TLPA: Fedlex, SR 955.3 (English translation, without legal force). A time limit in months is calculated under art. 77 para. 1 no. 3 CO. This page is not legal advice: read the text before any report.