# AMLR Art. 24 — Discrepancy reporting to BO register > TJPG in force 1 October 2026; the TJPG Art. 30 discrepancy-reporting duty applies only from 1 April 2027, six months after entry into force (TJPG Art. 54 Abs. 1). AMLR Art. 24 applies from 10 July 2027. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.24 - Transparency and beneficial ownership of legal persons|FATF R.24]] - **Swiss provisions:** [[TJPG Art. 30 - FI discrepancy report, 30 days|TJPG Art. 30]], [[TJPG Art. 31 - Authority discrepancy report|TJPG Art. 31]], [[TJPG Art. 32 - Entity discrepancy report (a right|TJPG Art. 32]], [[TJPG Art. 34 - Processing discrepancies; flag (Vermerk) on|TJPG Art. 34]] - **Detailed citation:** TJPG Art. 30 (FIs, 30 days), Art. 31 (authorities), Art. 32 (entities), Art. 34 (Vermerk/flag) > [!tip] In practice > - Swiss deadline: 30 days, and only after the customer had a chance to correct the discrepancy (TJPG Art. 30). > - AMLR deadline: 14 calendar days. A correct-first step is allowed only for minor or outdated-but-known discrepancies, and not in higher-risk cases. > - The Swiss duty binds financial intermediaries only, not advisers. It applies from 1 April 2027 (TJPG Art. 54); the AMLR applies from 10 July 2027. ## What it requires AMLR Art. 24(1) requires obliged entities to report to the central register any discrepancy between its data and what they hold under Art. 20(1)(b) and 22(7), within 14 calendar days of detection, naming who they consider the beneficial owner to be. Art. 24(2) lets minor or outdated-but-known discrepancies be resolved by inviting the customer to correct the register within 14 days, except in higher-risk cases. Art. 24(3) requires reporting anyway if the customer misses that deadline. Art. 24(4) exempts lawyers, notaries, auditors, accountants and tax advisors for information obtained when ascertaining a client's legal position or in judicial proceedings, unless the Art. 21(2) exceptions apply. ## Swiss position TJPG Art. 30 requires a financial intermediary under GwG Art. 2 Abs. 2/3 to report a discrepancy to the Transparenzregister within 30 days - but only once the customer has been given a reasonable deadline to correct it and the discrepancy still stands; the cure attempt is a precondition of reporting. TJPG Art. 31 requires authorities to report doubts directly to the register, with MROS reporting only where it will not jeopardise pending or prospective proceedings, and FINMA able to skip notifying the register if a financial intermediary has already reported under Art. 30. TJPG Art. 32 lets a legal entity itself flag discrepancies about its own entry. TJPG Art. 34 requires the register authority to annotate the entry on receiving a report, notify the entity, and set a correction deadline. ## Key divergences Both regimes build in a correction step before an outright report, but the sequencing differs: TJPG Art. 30 makes the customer's cure attempt a precondition of reporting, while AMLR Art. 24 requires the report within 14 calendar days and allows a cure-first step only for minor or outdated-but-known discrepancies, and not in higher-risk cases (Art. 24(2)-(3)). The reporting deadlines also differ - 14 calendar days under AMLR against 30 days under TJPG Art. 30(2). Scope differs too: TJPG Art. 30 binds only financial intermediaries under GwG Art. 2 Abs. 2/3; advisers under GwG Art. 2 Abs. 3bis/3ter get register access under TJPG Art. 27 but carry no discrepancy-reporting duty, while AMLR Art. 24 binds all obliged entities without that carve-out. The Swiss duty also starts later: under TJPG Art. 54 Abs. 1 the Art. 30 reporting duty applies only six months after the TJPG entered into force. Under Art. 54 Abs. 2, where a company is not yet registered and confirms that it falls under the two-year transitional period of TJPG Art. 51 Abs. 2, the financial intermediary need not report discrepancies until that period ends. ## Effective dates TJPG in force 1 October 2026; the TJPG Art. 30 discrepancy-reporting duty applies only from 1 April 2027, six months after entry into force (TJPG Art. 54 Abs. 1). AMLR Art. 24 applies from 10 July 2027. See [[Effective-dates timeline]]. ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 24 — English text (EUR-Lex, CELEX 32024R1624) > **Article 24** > *Reporting of discrepancies with information contained in beneficial ownership registers* > 1. Obliged entities shall report to the central registers any discrepancies they find between the information available in the central registers and the information they collect pursuant to Article 20(1), point (b), and Article 22(7). > The discrepancies referred to in the first subparagraph shall be reported without undue delay and, in any case, within 14 calendar days of their detection. When reporting such discrepancies, obliged entities shall accompany their reports with information they have obtained indicating the discrepancy and whom they consider to be the beneficial owners and, where applicable, the nominee shareholders and nominee directors to be and why. > 2. By way of derogation from paragraph 1, obliged entities may refrain from reporting discrepancies to the central register and may instead request additional information from the customers where the discrepancies identified: > (a) are limited to typographical errors, different ways of transliteration, or minor inaccuracies that do not affect the identification of the beneficial owners or their position; or > (b) are a result of outdated data, but the beneficial owners are known to the obliged entity from another reliable source and there are no grounds for suspicion that there is an intention to conceal any information. > Where an obliged entity concludes that the beneficial ownership information in the central register is incorrect, it shall invite the customer to submit the correct information to the central register pursuant to Articles 63, 64 and 67 without undue delay, and, in any case, within 14 calendar days. > This paragraph shall not apply to cases of higher risk to which measures under Section 4 of this Chapter apply. > 3. Where a customer has not submitted the correct information within the deadline referred to in paragraph 2, second subparagraph, the obliged entity shall report the discrepancy to the central register in accordance with paragraph 1, second subparagraph. > 4. This Article shall not apply to notaries, lawyers, other independent legal professionals, auditors, external accountants and tax advisors in relation to information they receive from, or obtain on, a client, in the course of ascertaining the legal position of that client, or performing their task of defending or representing that client in, or concerning, judicial proceedings, including providing advice on instituting or avoiding such proceedings, regardless of whether such information is received or obtained before, during or after such proceedings. > However, the requirements of this Article shall apply when the obliged entities referred to in the first subparagraph of this paragraph provide legal advice in any of the situations covered by Article 21(2), second subparagraph. ## Sources - AMLR Art. 24 - CELEX 32024R1624 - TJPG BBl 2025 2900, Art. 30, 31, 32, 34, 54 - GwG SR 955.0, Art. 2; GwG (rev. BBl 2025 2899, in force 1.10.2026), Art. 2 - TJPG BBl 2025 2900, Art. 27