Transparency register deadline check
Since 1 October 2026, companies limited by shares (AG), limited liability companies (GmbH), cooperatives and other legal entities must report their beneficial owners to the transparency register. Existing companies have staggered transitional deadlines. Newly formed companies and companies with a change in the commercial register have one month. The deadline check shows you in three steps which deadline applies to your company.
Deadline check
By when must your company report to the transparency register?
Three short steps, then you see your deadline and what to do.
Company
What is the company’s legal form?
Does an exemption apply?
Listed on a stock exchange or more than 75 % held by listed companies, at least 75 % owned by public authorities, or an occupational pension institution.
Commercial register
Since when has the company been entered in the commercial register?
Art. 51 TJPGThe act has applied since 1 October 2026. Companies entered before that date have transitional deadlines.
Has there been a change in the commercial register since 1 October 2026?
Art. 51 para. 1 TJPGFor example a new address, a change on the board or in management, an amendment to the articles. The first change shortens the deadline to one month.
Where do I find the date?
Owners and audit
Are all beneficial owners already entered in the commercial register?
Art. 51 para. 2 TJPGAs a member or officer, for example on the board or in management. In that case the deadline is two years.
Who is a beneficial owner?
Is the company subject to an ordinary audit?
Art. 51 para. 3 TJPGArt. 727 COMost SMEs have a limited audit or opt out of the audit.
When does the ordinary audit apply?
Non-binding assessment. The deadline check provides a non-binding recommendation based on the statutory provisions (TJPG, as of November 2026) and the information published by the federal government. It does not replace legal advice or an assessment of the individual case. Hoop gives no warranty as to accuracy, completeness or timeliness and accepts no liability for decisions based on the result. The law and the information of the competent authorities on transpareg.admin.ch are authoritative. Your entries are not stored.
The deadlines at a glance
For companies already entered in the commercial register on 1 October 2026, the transitional deadlines in Art. 51 TJPG apply. The legal form and the audit obligation are decisive:
| Company | Deadline | Date |
|---|---|---|
| All beneficial owners are already entered in the commercial register as members or officers (typically: GmbH with natural persons as members) | 2 years | 1 October 2028 |
| AG subject to an ordinary audit | 3 months | 1 January 2027 |
| Other companies subject to an ordinary audit | 4 months | 1 February 2027 |
| AG not subject to an ordinary audit | 5 months | 1 March 2027 |
| Other companies and legal entities (GmbH, cooperative without ordinary audit) | 6 months | 1 April 2027 |
| Foreign legal entities (Art. 53 TJPG) | 6 months | 1 April 2027 |
The deadlines run from entry into force on 1 October 2026 and end on the day with the same number, for example on 1 March 2027. This is also how the Federal Office of Justice counts.
Ordinary or limited audit?
Art. 727 CO determines whether a company is subject to an ordinary audit. This applies to public companies, to companies required to prepare consolidated accounts and to companies that exceed two of the following three thresholds in two consecutive financial years: balance sheet total of CHF 20 million, revenue of CHF 40 million, 250 full-time positions on annual average.
All other companies are subject to a limited audit (Art. 727a CO). If they have no more than ten full-time positions on annual average and all shareholders agree, they can opt out of the audit entirely. For the reporting deadline, a limited audit and opting out count the same: the longer deadline without an ordinary audit applies.
The type of audit is stated in the auditor’s report on the annual financial statements. If in doubt, the auditor can tell you.
When is the deadline shortened?
If a company changes anything in the commercial register after 1 October 2026, for example its address, its board or its articles, it must report within one month of this first change (Art. 51 para. 1 TJPG). The publication in the Swiss Official Gazette of Commerce (SOGC) is decisive.
Newly formed companies report within one month of their entry in the commercial register (Art. 9 para. 4 TJPG). Later changes, such as a change of beneficial owner, must also be reported within one month of becoming aware of them (Art. 10 TJPG).
Frequently asked questions about the deadlines
Is reporting to the transparency register subject to a fee?
No. Reporting is free of charge via EasyGov. Fees can only arise for reminders, demands and rulings by the authorities.
What happens if the deadline is missed?
The authority keeping the register checks no earlier than six months after entry into force whether a report was made and requests companies that have not reported to do so (Art. 52 TJPG). Reminders and rulings are subject to a fee. Anyone who intentionally breaches the reporting obligation can be fined up to CHF 500,000 (Art. 43 TJPG).
Does a GmbH with natural persons as members have a longer deadline?
Yes, as a rule. If all beneficial owners are entered in the commercial register as members or officers, the two-year deadline until 1 October 2028 applies (Art. 51 para. 2 TJPG). If anything changes in the commercial register before then, it is shortened to one month.
Where do I find the SOGC publication date?
In the commercial register extract, for example via Zefix. It shows the number and the publication date in the Swiss Official Gazette of Commerce for each entry.
Can Hoop submit the report for me?
Hoop is a private software provider, not an authority. In Hoop you keep the share register and the register of beneficial owners and prepare the report. It is submitted free of charge via EasyGov; on request, Hoop submits it for you under a power of attorney.
More about the transparency register
All rules, terms and the reporting process are covered in the Swiss transparency register guide. The product page shows how Hoop supports you with the register of beneficial owners. More answers are on the page Questions on share registers and the transparency register.
As of November 2026
