Insights

Switzerland’s transparency register sets a standard your KYC files should meet

Written by Jonathan Da Dalto | Oct 18, 2026, 8:30:42 AM

Switzerland’s federal register of beneficial owners began operating on 1 October 2026, the day the Federal Act on the Transparency of Legal Persons came into force. The Federal Office of Justice runs it. The register records the people who control Swiss legal entities and foreign legal entities with a Swiss connection. It is closed to the public: authorities, financial intermediaries and advisers with duties under the Anti-Money Laundering Act may consult it for those duties.

The Office has published how it protects the data. The system runs on a specially secured network and stores data only on a physical server in Switzerland. The number of queries is limited and access requires multi-stage authentication. Internal and external tests probe the system for vulnerabilities.

The register opened about two months after a breach in Liechtenstein. Overnight into 30 July 2026, an unknown perpetrator copied data on the beneficial owners of about 31,000 registered entities from the principality’s register, Liechtenstein’s government reported on 2 August.

Reporting deadlines started running on 1 October

Every legal entity the law covers must register once and then report each change to its beneficial owners. The Office’s guidance sets maximum periods by entity type:

  • Companies limited by shares subject to ordinary audit have three months.
  • Other companies subject to ordinary audit have four months.
  • Companies limited by shares that do not meet the conditions for ordinary audit have five months.
  • Other companies not subject to ordinary audit, other legal persons and foreign legal persons have six months.
  • Locate every SharePoint site, Teams channel and OneDrive folder that holds beneficial-ownership documents.
  • List who can open each one, including guests and sharing links that reach outside the company.
  • Apply sensitivity labels, Microsoft’s tags that classify and protect a file, to the most sensitive documents; where a label encrypts a file, Copilot honours the usage rights the label grants the user.
  • Test what Copilot returns for a user with ordinary access before extending it across the company.

The first change to an entity’s commercial register entry after 1 October 2026 brings its deadline forward to one month from publication of the change in the Swiss Official Gazette of Commerce. Where every beneficial owner already appears in the commercial register as a partner or officer, the entity has two years. Foundations fall outside the law, although a foundation can sit in the control chain of a company that must report.

Reporting deadlines by entity type

Maximum periods
3 months
Companies limited by shares subject to ordinary audit.
4 months
Other companies subject to ordinary audit.
5 months
Companies limited by shares that do not meet the conditions for ordinary audit.
6 months
Other companies not subject to ordinary audit, other legal persons and foreign legal persons.
Two rules that override them
1
month
After an entity’s first commercial register change following 1 October 2026, counted from publication in the Swiss Official Gazette of Commerce.
2
years
Where every beneficial owner already appears in the commercial register as a partner or officer.

Your client files hold the same facts

The register is the Confederation’s record. Every financial intermediary in Geneva keeps its own: the know-your-client files, or KYC files, in which it establishes who each client’s beneficial owner is and keeps the records the Anti-Money Laundering Act requires. Trustees and family offices hold the same material for the structures they administer.

Where those files sit in SharePoint, Teams or OneDrive, they are within reach of Microsoft Copilot, the assistant built into Microsoft 365. Microsoft’s documentation says that Copilot “only surfaces organizational data to which individual users have at least view permissions”. It applies the permissions it finds. A client folder shared too widely years ago can then be summarised for any colleague who can open it.

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Microsoft 365 Copilot only surfaces organizational data to which individual users have at least view permissions.
Microsoft Learn

 

Check where client files sit and who can open them

The questions the Office answered for the register apply to these files:

The Confederation has set out where its copy of these facts lives and who may query it. A compliance officer should be able to say the same of yours. Put this on your agenda, we can help you get there.

References

  1. Swiss Confederation (2025) Federal Act of 26 September 2025 on the Transparency of Legal Persons and the Identification of Beneficial Owners (TLPA), SR 955.3. Fedlex, English translation (no legal force), status as of 1 October 2026.
  2. Federal Office of Justice (2026) Transparenzregister nimmt den Betrieb auf. Press release, 1 October 2026. German; no English version published.
  3. Federal Office of Justice (n.d.) Fragen und Antworten. TranspaReg, transpareg.admin.ch; section on transitional periods under Article 51 of the Act. Accessed 14 October 2026.
  4. Government of the Principality of Liechtenstein (2026) Unberechtigter Zugriff von Dritten auf Verzeichnisdaten. Press release, 2 August 2026. Also published on presseportal.ch.
  5. Microsoft (n.d.) Data, Privacy, and Security for Microsoft 365 Copilot. Microsoft Learn. Accessed 14 October 2026.