The 2026 revision of the Swiss Anti-Money Laundering Act changes the regulatory landscape. Certain professional advisory services may become subject to the Act, while the new transparency register creates additional duties for legal entities. This article explains the main changes and the steps businesses should take before 1 October 2026.
Entry into force and purpose of the reform
The Federal Council has brought the revised Anti-Money Laundering Act and the Act on the Transparency of Legal Entities and the Identification of Beneficial Owners into force on 1 October 2026. The reforms pursue a common objective: improving transparency over ultimate control and strengthening the preventive framework for higher-risk services.
Businesses should distinguish the two strands. The transparency register creates reporting and updating duties for legal entities. The AMLA revision, by contrast, expands the range of professional activities for which service providers may have to comply with anti-money laundering due diligence.
No automatic sector-wide coverage
A law firm, fiduciary company, notarial organisation or consultancy is not covered merely because of its label. The decisive question is what services are actually provided and how the business participates in a transaction.
Professional advisory services that may be covered
The focus is on activities in which a service provider actively participates in financial or structural arrangements for a third party. This may include preparing or carrying out certain transactions, forming or administering non-operating entities and providing a registered office.
- Participation in certain purchases or sales of real estate and connected financial steps.
- Formation, structuring, management, administration or transfer of non-operating companies and other entities.
- Organisation of contributions, distributions or transfers of assets involving such structures.
- Provision of a business address, premises or domicile over a relevant period.
- Other financial intermediary activities such as payment services or custody and management of certain assets.
The legal assessment follows substance rather than invoice wording. General information may be treated differently from drafting transaction documents, coordinating payments, providing corporate officers or implementing the structure itself.
Professional activity and thresholds
The new advisory provisions apply to activities carried out professionally. Under the criteria used for the initial assessment, professional activity should be examined in particular when at least one of the following thresholds is met.
| Criterion | Threshold |
|---|---|
| Gross revenue | More than CHF 50,000 per calendar year |
| Clients or legal transactions | More than 20 per calendar year |
| Third-party assets | More than CHF 5 million at any time |
| Transaction volume | More than CHF 2 million per calendar year |
The thresholds are not a substitute for identifying the activity. A business should first determine which services could fall within a statutory category, then calculate the relevant revenue, cases, assets or transactions attributable to those services.
Example
A consultancy occasionally helps establish operating start-ups but does not administer them, handle payments or provide officers. The number of engagements alone does not answer the applicability question. The actual services must first fall within a relevant statutory category.
Transparency register and beneficial ownership
The Swiss transparency register records the natural persons who ultimately control legal entities. It is maintained by the Confederation and is intended to give designated authorities more reliable access to beneficial ownership information.
Legal entities will have their own reporting and updating duties. For AMLA-subject service providers, the register is an important source but does not replace collecting information from the client, checking plausibility and documenting inconsistencies.
Corporate reporting duties, client due diligence and internal risk processes should therefore use consistent ownership and control data.
Consequences of AMLA applicability
Confirmed applicability is not a one-off registration exercise. It creates ongoing organisational and client-related duties. Depending on the category, this includes joining a self-regulatory organisation, appointing responsible persons and establishing an auditable control framework.
- Identify the contracting party and verify representation rights.
- Identify and document beneficial owners or controlling persons.
- Understand the purpose, background and plausibility of the relationship or transaction.
- Assign a risk rating, conduct enhanced checks for higher risks and screen relevant sanctions lists.
- Maintain a complete file, keep it current and retain records appropriately.
- Establish internal rules, training, controls, reporting procedures and periodic audits.
These duties must be completed in a repeatable way before or during the relationship. A checklist alone is insufficient where responsibilities, deadlines and escalation routes remain unclear.
How businesses should prepare
- Inventory all services and actual process steps.
- Map each service to possible statutory categories and document exemptions.
- Assess professional scale using revenue, case numbers, third-party assets and transaction volume.
- Obtain specialist advice for unclear situations.
- Compare possible SROs and clarify admission requirements early.
- Prepare responsible roles, internal rules, training, onboarding and file management.
- Align data used for the transparency register and AMLA checks.
A documented negative conclusion is also valuable. It demonstrates that the business considered the issue and makes future reassessment easier when services or the legal framework change.
Frequently asked questions
Does the revision definitely enter into force on 1 October 2026?
Yes. The Federal Council set 1 October 2026 as the effective date for the revised AMLA and the transparency legislation, subject to specific transitional arrangements.
Are all lawyers, notaries and fiduciaries newly subject to the AMLA?
No. The actual activity, professional scale and applicable exemptions are decisive. A professional title alone is not enough.
Does the transparency register replace client due diligence?
No. It supports transparency but does not replace identification, clarification and documentation duties.
What is the first practical step?
Create a complete list of services and process steps, then map each one to possible applicability grounds.