Switzerland sets 1 October 2026 start for beneficial-ownership register and advisory AML duties
Swiss legal entities must register their beneficial owners and high-risk advisory providers must apply new AML due diligence from 1 October 2026
Change
On 12 June 2026 the Swiss Federal Council set 1 October 2026 as the entry-into-force date for the revised Anti-Money Laundering Act and the new Act on the Transparency of Legal Persons and the Identification of Beneficial Owners, establishing a beneficial-ownership transparency register and extending AML due-diligence duties to certain threshold-defined high-risk advisory activities.
Why it matters
The two Parliament-approved acts and their ordinances enter into force on 1 October 2026, which also starts the transition periods for registering affected legal entities in the new beneficial-ownership transparency register. The revised Anti-Money Laundering Ordinance introduces thresholds defining which professional advisory activities fall within the new due-diligence requirements. Provisions on state notaries (Amtsnotare) are postponed to let cantons adapt their legislation. The Federal Council set the date to allow implementation time and to enable the Financial Action Task Force to assess the measures in its 2027-2028 evaluation of Switzerland.
Implications
- — In-scope Swiss legal entities must prepare to register their beneficial owners in the new federal transparency register from the 1 October 2026 start of the transition periods — the registration window opens on that date, so entities must identify their beneficial owners and map the filing obligation before it begins.
- — Advisory providers performing the newly covered high-risk activities must determine whether they cross the professional-activity thresholds set in the revised Anti-Money Laundering Ordinance and, where they do, stand up AML due-diligence controls before 1 October 2026 — the duties attach to threshold-crossing advisory activity from that date.
- — Cantonal commercial registers must implement the new beneficial-ownership tasks assigned to them under the Transparency Ordinance, as the register's operation depends on their handling of registration, in a form the Federal Council has sought to make simpler and more cost-effective.
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