Switzerland corporate onboarding: documents, risks and rules
Swiss commercial-register evidence is particularly useful for checking representation, including whether signatures must be given together. It is less uniform as ownership evidence: a GmbH's registered quota holders differ from the shareholder information available for an AG.
By Matthew Lee
Swiss commercial-register evidence is particularly useful for checking representation, including whether signatures must be given together. It is less uniform as ownership evidence: a GmbH's registered quota holders differ from the shareholder information available for an AG. The onboarding file should use the competent canton’s record to establish authority, then obtain the ownership and business evidence that the public register does not supply.
Which rules apply
Swiss financial intermediaries within scope follow the Anti-Money Laundering Act and the rules applicable to their supervisory or self-regulatory framework. These address contracting-party identification, beneficial ownership and clarification of relevant relationships and transactions. FINMA-regulated institutions also follow applicable FINMA requirements. The correct evidence and escalation process depend on the institution and relationship; incorporation in Switzerland alone does not decide which AML regime an overseas onboarding firm applies.
The duties follow the onboarding firm's location, regulatory status and service. An overseas firm applies its own relevant regime to this customer. Ordinary commercial counterparties can also use these records for risk assessment without having the same duties as regulated firms.
Documents commonly requested
The starting file should reflect the legal form and the proposed relationship. These records answer complementary questions:
| Evidence | What the reviewer looks for |
|---|---|
| Current cantonal commercial-register extract | Name, UID, legal form, seat, management and signing rights |
| Relevant SHAB notices and articles | Changes in officers, names, seat or governance |
| GmbH quota-holder or appropriate AG shareholder evidence | Immediate ownership for the customer's legal form |
| Ownership chart and supporting control records | Corporate layers and the relevant natural persons |
| Identity evidence and mandate | Individuals and the required signature or delegation |
| Financial and commercial evidence | Actual activity, expected payments and source of funds |
Registry records establish facts within their stated scope. Current ownership records, identity evidence and mandates may need to come from the client or another permitted source. Keeping those origins visible helps explain differences and the extent of independent corroboration.
The risks behind the paperwork
A collective signature needs the stated combination. An extract may record individual or collective signature rights. A director's presence in the record therefore does not necessarily support accepting their instruction alone. The current entry and any relevant mandate should explain the combination required. Where the instruction concerns an earlier transaction, officer changes need to be assessed by date rather than assuming today's extract establishes historical authority.
An AG register entry does not reveal every shareholder. The commercial register can show a GmbH's registered quota holders, while an AG generally requires separate ownership evidence. Managers and authorised signatories should not be treated as owners merely because their names are publicly available. Current shareholder records and declarations need to explain corporate layers, voting rights and relevant control, with supporting documents for the parts that cannot be independently corroborated from public sources.
A cross-cantonal move can explain the history. Zefix helps identify the entity and locate the competent cantonal record. A company that moves its seat may have older documents from another canton without becoming a different customer. The UID and relevant registered notices help establish continuity. A similarly named company with another identifier, however, needs its own assessment; shared branding or an address does not make two legal persons interchangeable.
Swiss public registration is not a universal source of company accounts. The reviewer may need current financial statements directly from the client to assess credit exposure or explain funding. For regulated services, the competent supervisory source should identify the actual legal entity and permission, rather than relying on a broad business purpose in the commercial-register record.
How the Fill Easy email bot helps
An approved organisational sender can request available registry documents from agent@fill-easy.com, using prose, a table or an attached spreadsheet. Include the company identifier and required documents:
Please retrieve a current commercial-register extract, relevant SHAB notices and available corporate documents for [company name], UID [CHE identifier], canton [canton]. Reference: [case reference]. Please include a summary report and confirm availability, price and expected turnaround.
The agent replies with item statuses, asks for clarification where needed, and returns retrieved PDFs in the same thread. Results carry their source, retrieval time and request ID. An optional summary references the documents. Availability, price and expected turnaround are confirmed at acceptance.
This helps the team collect and reconcile the registry evidence. Client-held records and individual identity evidence still follow the appropriate process, while the reviewer resolves remaining gaps and makes the onboarding decision. See the Mailbox workflow for the email process.