Contact us
Switzerland – Introduction of a UBO Transparency Register
On the 26th of September 2025, the Swiss Parliament adopted the Federal Act on the Transparency of Legal Entities and Identification of Beneficial Owners (LETA) together with revisions to the Anti‑Money Laundering Act (AMLA). These reforms introduce a new central transparency register for Ultimate Beneficial Owners (UBOs) in Switzerland.
Once in force, Swiss legal entities will be required to identify, verify, and report their UBOs to the register. Non‑compliance may result in fines of up to CHF 500,000.
The introduction of the new reporting obligations is expected in the second half of 2026. The precise effective date remains subject to confirmation by the Swiss Federal Council.
Regulatory Background
Under LETA, Swiss legal entities must proactively identify their UBOs using a risk‑based approach. UBO information must be verified with due care and always maintained in a secure and accessible manner within Switzerland.
Key obligations include:
- Maintaining current UBO records in Switzerland
- Retaining records relating to former UBOs for ten years following the loss of UBO status
- Reporting UBO details to the central register, including the nature and extent of control
- Notifying the register of any changes to UBO information within one month
- Reporting cases where UBO identification or verification cannot be fully completed
Where no UBO can be satisfactorily identified or verified, the Swiss legal entity must report the relevant information together with the identity of the highest member of the executive body.
Applicability and Scope
| LETA applies to: | |
|---|---|
| Swiss legal entities, including: | • Aktiengesellschaften (AGs) • Gesellschaften mit beschränkter Haftung (GmbHs) • Cooperatives • SICAVs and SICAFs • Limited partnerships for collective investments |
| Foreign legal entities with a Swiss nexus, including those with: | • A Swiss branch • Effective management in Switzerland • Swiss real estate holdings |
| Exemptions apply to: |
|---|
| • Listed entities (wholly or partially listed) • Subsidiaries majority owned (more than 75%) by a listed company |
UBO Definition
A UBO is defined as any natural person who ultimately controls the entity, whether:
- Directly or indirectly holding at least 25% of the capital or voting rights, or
- Exercising control through other means
UBO Registration Requirements
The following information must be reported for each identified UBO:
- Full name
- Date of birth
- Nationality
- Residential address and country of residence
- Nature and extent of control exercised
Where an entity is partially owned by a listed company, additional disclosure is required, including:
- Name and registered seat of the listed company
- Details of the relevant stock exchange listing
In cases where UBO identification or verification is incomplete, all reasonable investigative steps must be fully documented and submitted, together with the required executive‑level information.
Access to the UBO Register
UBO information will not be publicly accessible. Access to the register will be restricted to competent authorities and other persons specifically designated under Articles 26 and 27 of LETA, solely for the performance of their statutory functions.
Risks of Non-Compliance
LETA provides for strict sanctions in the event of non‑compliance, including:
- Administrative fines of up to CHF 500,000
- Potential criminal liability for the natural person responsible for UBO reporting (generally the highest member of the executive body)
The Swiss legal entity itself will only be held liable under limited circumstances, primarily where the responsible individual cannot be identified despite reasonable efforts.
How Mercator® by Citco (Mercator) Can Help
Mercator can assist with navigating UBO requirements under LETA, including guidance on legal obligations, support with UBO identification and verification, and preparation for reporting and filing once the regulation comes into force.
For assistance, please contact mercator@citco.com.
