Beneficial owners across 300 entities: for the transparency register, 60% of 30% is not 18%
Your client owns 60% of a holding company, which owns 30% of a Swiss company you administer. Multiply, and you get 18%, well under the 25% line. The new ordinance does not multiply: more than half of a company that holds at least 25% is control, so your client is a beneficial owner. Someone with 40% of a holding that owns all of it may not be, through the shares. Now picture that across 300 entities, with share registers kept in three places and extracts from years ago. Would you draw every chain the same way twice?
The short answer: since 1 October 2026, companies limited by shares, limited liability companies, cooperatives, SICAVs, SICAFs and limited partnerships for collective investment, and some foreign entities, must identify the natural persons who control them, verify them with due care, keep the file current and accessible in Switzerland, and report them to the new transparency register. Control means at least 25% of the capital or votes held directly, more than 50% of an intermediate company that itself holds at least 25%, or control by other means, such as the right to appoint most of the board. Existing companies have three to six months, or two years if all their beneficial owners are already in the commercial register, and a month after their next change in the commercial register if that comes first; every later change is reported within a month. A local AI, on servers in Switzerland, Meow's or your own, can read the extracts, share registers, structure charts and deeds, draw each chain with the page it rests on, and flag what does not match, while a person decides.
Checked against the law on 30 September 2026
Who really owns it?
- More than 50%
Through an intermediate company, what counts is holding more than 50% of it, when it holds at least 25% of yours. Percentages are not multiplied down the chain (Transparency Ordinance, arts. 1 and 2).
- 1 month
To report any change to the register once the company knows of it; shareholders who gain control must tell the company within a month too. Intentional failures to report are fined up to CHF 500,000 (Transparency Act, arts. 10, 13 and 43).
- 1 April 2027
From this date, banks and other financial intermediaries that find a difference casting doubt on the register must ask the client to correct it, then report it within 30 days (Transparency Act, arts. 30 and 54).
How to rebuild each chain
0 of 8 checked
Companies limited by shares, limited liability companies, cooperatives and collective investment companies are in. Listed companies and their subsidiaries more than 75% held, pension institutions, and entities at least 75% held by public bodies are out (Transparency Act, arts. 2 and 3).
The commercial register extract, the share register or register of members, the structure chart, shareholders' agreements, the articles, and any loan or option that carries rights. Note each one's date.
At least 25% held directly, or more than 50% of an intermediate company that holds at least 25%, directly or indirectly, in capital or in votes (Transparency Ordinance, arts. 1 and 2).
The right to appoint or remove most of the board, a veto on strategy, budget or financing, or the power to bring about distributions, through shareholders' agreements, options, convertible loans, the articles, representation or fiduciary arrangements (Transparency Ordinance, art. 3).
People who coordinate to control the company count together: two holders of 15% who vote as one reach 30% (Transparency Ordinance, arts. 4 and 13).
Then the top member of the management body is reported: the chair of the executive board, or the chair of the board of directors if there is no separate executive board (Transparency Act, art. 4; Transparency Ordinance, art. 20).
Name, date of birth, nationalities, municipality, postcode and country of residence, the AHV number or else a copy of a passport or identity card, how control is held, and its band: 25 to 50%, over 50 to 75%, over 75% (Transparency Ordinance, arts. 10, 12 and 13).
Three to six months from 1 October 2026 by legal form and audit, two years if every beneficial owner is in the commercial register, or a month after the next change there if sooner; and a written authorisation, signed as registered, for whoever files on the platform (Transparency Act, art. 51; Transparency Ordinance, art. 27).
Ticked them all? The kit turns this into work for your whole book: six chains answered, the eight checks for a register-ready entity file, the rules that make an AI flag what does not match, and a plan to test it on your own entities. Get the kit
Owner or not? Six chains
The kit answers six common chains. Two of them:
- 60% of a holding that owns 30% of the company
- A beneficial owner: more than 50% of an intermediate company that holds at least 25% is control. The 18% you get by multiplying plays no part (Transparency Ordinance, art. 2).
- 40% of a holding that owns 100% of the company
- Not through the shares: indirect control needs more than 50% of the holding. Check control by other means and acting in concert before you conclude (Transparency Ordinance, arts. 2 to 4).
- Two siblings with 15% each, voting as one
- In the kit
- A private investor's convertible loan with a veto on the budget
- In the kit
- A subsidiary 80% held by a listed group
- In the kit
- No one above 25%, and no other control
- In the kit
From April 2027, the bank compares
Financial intermediaries that find a difference between the register and their own files, one that casts doubt on it, must point it out to the client, allow reasonable time to correct it, then report it within 30 days. A different spelling of a name or an extra first name is not such a difference (Transparency Act, arts. 30 and 54; Transparency Ordinance, art. 56). Unlike the commercial register, online access is limited to the control body and authorities the act lists, and to financial intermediaries and advisers for their checks; each entity can order confirmations and extracts of its entry (Transparency Act, arts. 25 to 28).
Where a local AI helps
Three hundred entities means three hundred chains to redraw, each from a pile of extracts, registers and agreements. A local model reads them, draws each chain with the page behind every link, and lists what is out of date, missing or contradictory, while a person decides and signs. The files hold passports and ownership chains, so they stay on servers in Switzerland, Meow's or your own.
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