《物权法》出台后,我国物权变动的立法模式已明确为登记生效主义,但并没有明确具体采用德国模式还是瑞士模式。经过对大陆法系三种物权变动立法模式法国主义、德国主义、瑞士主义的比较,本文认为瑞士主义兼取了前两者之长,弥补了前两者之短,以其结构上的优势以及对我国国情的适应性成为我国不动产物权变动立法模式的当然选择。 After the promulgation of the Property Law, the legislative mode of the change of real rights in our country has been explicitly registered as a valid doctrine. However, the German model or the Swiss model has not been explicitly adopted. After comparing the three legislative modes of the change of real rights in the civil law system: French, Germanism and Swissism, this article holds that Swissism has made up for the shortcomings of the first two and the structural advantages As well as the adaptability to our national conditions have become the natural choice of the legislative mode of the real property change in our country.