From October 1, 2026, certain advisory services particularly exposed to money laundering risks will be subject to the Swiss Anti-Money Laundering Act (AMLA). An accounting firm will not be subject to these rules solely because it keeps accounts or prepares tax returns.
IN BRIEF
Whether the rules apply depends on the specific service provided and whether it is carried out on a professional basis. The activities must therefore be classified and the thresholds assessed across all advisory services covered by the rules.
Why fiduciaries need to review their services
As of October 1, 2026, certain individuals who professionally provide advisory services particularly exposed to money laundering risks will be classified as "advisors" under the AMLA. Accounting firms, accountants, lawyers, and corporate service providers may be affected.
The determining factor is not the professional label. A accounting firm is not subject simply because it keeps accounts or prepares tax returns. Conversely, a secondary activity may suffice when it falls within the legal catalog and exceeds one of the professional thresholds.
Which activities can bring a provider within the scope of the rules?
The law targets certain operations related notably to the creation, structuring, administration, or domiciliation of entities, as well as certain real estate transactions and operations on asset values. For a accounting firm, the following situations deserve particular examination :
- preparing or carrying out the creation, modification, or restructuring of a company or a legal construction ;
- organizing or administering a non-operational entity or an asset structure ;
- providing an address or premises as a domicile or headquarters for more than six months ;
- intervening in certain transactions on behalf of a client, notably real estate or involving asset values ;
- exercising certain functions or providing specialized services related to the administration of a company or a trust.
The qualification must be examined service by service. The actual content of the mandate prevails over its title: renaming a domiciliation "premium administrative service" obviously does not change its substance.
What ordinary services are not automatically targeted ?
Bookkeeping, payroll preparation, the preparation of a tax return, or ongoing tax advice do not, by themselves, make the accounting firm a "consultant" subject to the LBA. However, these services may be part of a broader mandate that includes an activity covered by the law.
It is therefore necessary to avoid two opposing errors: applying LBA procedures to all mandates without distinction, or considering that a accounting firm can never be concerned because its core business remains accounting and tax.
The decisive role of professionalism thresholds
Even when a service belongs to the legal catalog, the qualification as a consultant implies that it is exercised on a professional basis. This characteristic is notably achieved when at least one of the following thresholds is exceeded:
| Criterion | Threshold |
|---|---|
| Annual gross income from the targeted consulting activities | More than CHF 50,000 |
| Clients advised or legal operations concerned | More than 20 per year |
| Assets of third parties concerned by the consulting | More than CHF 5 million |
| Total volume of financial transactions concerned | More than CHF 2 million per year |
The application of these criteria requires sufficiently precise accounting and monitoring. One should not confuse the overall revenue of the accounting firm with the gross income from only the potentially taxable services.
Domiciliation of more than six months: the sensitive point
The provision of an address or premises as a domicile or headquarters for more than six months is expressly among the services that may fall under the status of consultant. Accounting firms offering domiciliation must therefore list their contracts, their duration, the nature of the domiciled companies, and the additional services provided.
An isolated domiciliation does not necessarily lead to qualification if the activity does not reach any threshold of professionalism. Conversely, several domiciliations combined with the creation or administration of companies can quickly exceed a threshold. The analysis focuses on all the targeted services, not on each contract taken artificially apart.
What obligations apply to regulated providers?
An adviser subject to the rules must, in particular:
- identify the contracting party and verify their identity;
- identify and verify the beneficial owner;
- clarify the purpose, nature, and economic background of the service or transaction;
- document the verifications and keep the records;
- establish an internal organization, a risk analysis, and appropriate training;
- examine unusual relationships or transactions and, if applicable, comply with the obligation to report to the MROS.
The advisor must also be affiliated with a recognized self-regulatory organization, unless there is a specific oversight regime. Individuals who become subject upon the entry into force have a short transitional period: the application for affiliation must be submitted within two months, generally before December 1, 2026. It would be wise not to wait until the last day; affiliation files rarely have the good taste to fill out overnight.
Practical method for a fiduciary
- Establish a complete inventory of services: accounting, taxation, creation, restructuring, domiciliation, administration, real estate operations, and transactions.
- Qualify each service in relation to the legal catalog, documenting the reasoning for borderline cases.
- Separate the revenues from potentially subject activities either account-wise or analytically.
- Measure the four thresholds of professionalism and provide an alert before they are crossed.
- Decide whether certain services should be maintained, limited, priced differently, or abandoned.
- If the subjection is likely, quickly choose an OAR and prepare internal procedures, responsibilities, training, and file templates.
- Adapt the engagement letters and general conditions to specify the information that the client must provide and the consequences of a lack of collaboration.
The opposing viewpoint: why subjection can be discussed
An authority or an OAR could adopt a functional reading and consider that a set of services constitutes a taxable activity, even when each is presented separately. The advisor will argue instead that certain interventions remain purely administrative, accounting, or tax-related and do not contribute to the preparation or execution of an operation targeted by the law.
The boundary will depend in particular on the degree of involvement, the power of representation, the structure concerned, the duration of the mandate, and the role played in the operation. For significant cases, a written position from a specialist or the considered OAR provides better protection than a mere internal intuition, even a very friendly one.
What clients need to understand
The new verifications do not reflect personal distrust. They result from a legal obligation. The client must provide accurate information about their identity, the economic beneficiaries, the purpose of the operation, the origin of the assets, and the control structure when these elements are relevant.
A well-organized accounting firm can integrate these controls into a clear and proportionate process, without turning each mandate into a banking interrogation. The goal is to secure the operations that are genuinely exposed while maintaining the fluidity of ordinary services.
How Delta Conseil SA can assist you
We can analyze with the executives the obligations related to their structure, prepare information on the economic beneficiaries, and coordinate the necessary steps. For particularly complex LBA subjection issues, the intervention of a specialist or the relevant OAR may be required.
CAUTION
This article provides a general overview of the law applicable as of August 28, 2026. Subjection depends on the facts and the crossing of legal thresholds. An individualized analysis is essential before concluding that a service is subject to or excluded from.
Frequently asked questions
Do all fiduciaries become subject to the LBA?
No. Only certain activities carried out professionally are targeted. Ordinary accounting and tax advice alone are not sufficient to trigger advisor status.
Does a domiciliation always lead to subjection?
Not automatically. The service must correspond to the legal case, particularly regarding its duration, and the activity must reach at least a threshold of professionalism. However, all relevant services must be taken into account.
What happens if a threshold is crossed during the year?
The status must be immediately reassessed, the required obligations applied, and the affiliation request submitted within the legal timeframe. Periodic monitoring of the thresholds is therefore necessary.
Can we simply waive the relevant services?
Yes, provided that this decision is real, reflected in the mandates, and respected in practice. An exclusion stated in the general terms is not enough if the team continues to carry out the activity.
Official sources
- Press release from the Federal Council of June 12, 2026
- Amendment to the AMLA
- Anti-Money Laundering Act
- FIU information
Last legal review: August 28, 2026.
Warning
This publication is provided for informational purposes and does not constitute individualized legal, tax, accounting, or financial advice. The situation must be assessed in light of the specific circumstances and the applicable law at the time of the decision.
For more information, please see our Legal notices and warning.
