Information on the Transparency Register (TJPG) and the Anti-Money Laundering Act (GwG)

Information on the Transparency Register (TJPG) and the Anti-Money Laundering Act (GwG)

Effective October 1, the Transparency Register Act (Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG)) will take effect. Public limited companies must therefore enter their beneficial owners in the Transparency Register by February 28, 2027 (public limited companies that have undergone a regular audit must enter the information by December 31, 2026; other companies have a 4- or 6-month deadline to do so). Owners of a limited liability company (GmbH) have a two-year deadline; registration must therefore be completed by September 30, 2028. However, if any change occurs in the Commercial Register after October 1, 2026, a short 30-day deadline for updating the transparency register begins once the change is published.

Specifically, we therefore recommend updating the share register or creating one if one does not yet exist. If there is a holding structure between your company and the private shareholders, the entire structure must be updated all the way down to the ultimate shareholder.

The Transparency Register is maintained online via EasyGov, which is now live following a lengthy testing phase. We therefore also recommend that you sign up for EasyGov now if you do not yet have access to it. With access via EasyGov and the current share register, you are ready to enter data into the Transparency Register.

We’d be happy to assist you with the Transparency Register entry; please contact us for more information. Specifically, it is possible, for example, to delegate your EasyGov access to us.

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