Transparency may not improve when information is stored in one more place. A register can make relevant ownership information accessible. Its value still depends on the quality of the data and the responsibilities surrounding it.
Switzerland’s new transparency legislation and revised anti money laundering legislation take effect on 1 October 2026. Transitional periods for registration begin then. Entry into force should therefore not be confused with a requirement that every affected entity already be registered on that day.
For implementation, I would focus on a few operational questions. Who obtains information about beneficial ownership? Who keeps it current? Who examines differences between company documents and register information? A process becomes fragile when everybody assumes that another participant has answered those questions.
A discrepancy deserves clarification. Its meaning depends on the facts, and the required next steps depend on the applicable duties. Treating every difference identically can produce activity without improving understanding. Ignoring differences would be equally unhelpful.
Swiss SMEs need requests they can understand and fulfil without unnecessary repetition. If several departments ask for the same document because responsibilities are unclear, the burden grows while the information may remain unchanged. Coordination is a contribution to proportionate implementation.
I would also distinguish possession of data from understanding of control. A name in a record is useful only when the relevant relationship is clear for the task at hand. Updates should preserve that understanding when circumstances change.
As a CEO, I would judge the process by whether it produces more reliable knowledge of ownership and control, with a clear route for resolving uncertainty. The number of forms completed is a weak measure of that achievement.
Good implementation gives each important information item an owner inside the organisation.
Who in your business is responsible for keeping such information accurate, rather than collecting it?