70 submissions from 64 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 82 submissions on this file. Shown here: the 70 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
53 submissions from industry — companies and their trade associations — against 10 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 5.3 industry submissions for every one from civil society.
Industry 53Civil society 10Public authorities, academia, other 7
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
38 of 64
in the EU Register
182
full-time lobbying staff
€31.7M+
declared costs a year
173
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 29 Jun 2018 — it ran from 26 Apr 2018.
29 June 2018 GSA COMMENTS ON THE PROPOSED REGULATION ON PROMOTING FAIRNESS AND TRANSPARENCY FOR BUSINESS USERS OF ONLINE INTERMEDIATION SERVICES We, the German Startups Association appreciate the opportunity to share our view on the Proposal for a “Regulation of the European Parliament and of the Council on promoting fairness and transparency for business users of online intermediation services” (COM(2018) 238…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
You will find attached the Position Paper of Ecommerce Europe. We overall welcome the publication of the European Commission’s Proposal for a Regulation on fairness and transparency in online platform trading. In particular, the European e-commerce association appreciates and supports the soft-touch and principle-based approach proposed by the Commission.
The GSMA welcomes the European Commission’s targeted approach aimed at tackling a number of identified issues with regard to the contractual relationships between online platforms and their business customers. - A EU-wide approach to imbalances surrounding lack of transparency, unilateral change of terms and conditions, delisting and ranking of users is necessary to address legal fragmentation in the single market…
Bitkom appreciates the opportunity to give feedback on the Proposal for a Regulation on Promoting Fairness and Transparency for Users of Online Intermediation Services, voicing the consolidated opinion of its affected members as stated in the attached position paper.
The Chamber of Commerce of Spain considers it necessary to make progress in the regulation of online platforms, thus providing small businesses with a safety net in the digital economy. Therefore, in order to have a regulatory context consistent with technological and social advances, and avoid the possible uncertainty and costs associated with an indefinite regime, it is positive to delimit the terms of the new…
D-0618-160-DM June 2018 HOTREC position on the proposal for a Regulation on promoting fairness and transparency for business users of online intermediation services HOTREC welcomes the proposal for a Regulation on promoting fairness and transparency for business users in online intermediation services (COM(2018)238 final). As highlighted in the Commission proposal, online intermediated services (e.g.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
1. General One of the vital underpinnings of ESBG is responsible banking. To that end ESBG supports all legislative and other initiatives that benefit consumers as it is of great importance to ESBG that consumers feel that they are treated fairly. Only then can they genuinely be happy with the services provided to them by ESBG members.
The German insurance industry welcomes the Commission’s proposal for a regulation promoting fairness and transparency for business users of online intermediation services and online search engines. Insurance companies are affected to varying degrees by the platform industry.
The International Mediation Institute (IMI), registered on the EU Transparency Register and based in the Hague, is the international standards-setting body for mediation and mediators worldwide. With representation at the UN ECOSOC and performing as a key part of UNCITRAL's Working Group II on the Convention on the Enforcement of Mediated Settlements, IMI is a thought leader on the use of mediation in dispute…
Good Afternoon, The attached cover letter and comments are sent on behalf of the American Bar Association Sections of Antitrust Law and International Law. These same comments were sent on June 18, 2018 in error. Regards, Deborah D. Morgan Assistant Director ABA Section of Antitrust Law 321 North Clark Street Chicago, IL 60654 [email removed]
21 June 2018 Comments of ACT | The App Association (Transparency Reg. # 72029513877-54) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels to The European Commission’s Directorate-General for Communications Networks, Content and Technology on its Regulation on promoting fairness & transparency for users of online intermediation services COM(2018) 238 I.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The current proposal has a major effect on businesses we represent, affecting a wide range of platforms, SMEs, startups, application developers, including companies that are involved in a process of transformation of its business model towards the model of the platform.
Filed in Spanish · English published by the European Commission
EACA welcomes the opportunity to provide comments on the European Commission’s proposal for a Regulation on promoting fairness and transparency for business users of online intermediation services (COM(2018)238/974102). EACA already submitted a response to the Inception Impact Assessment in November 2017.
Deutsche Bank welcomes the opportunity to provide comments on the transparency and redress measures included in the proposed Regulation. We support the Commission’s objective of addressing unfair business practices of online platform services which can be harmful to the legitimate interests of their business users and, ultimately, consumers in the Union.
Good Afternoon, Re: Joint Comments on the European Commission's Proposal for a Regulation Promoting Fairness and Transparency for Business Users of Online Intermediation Services. These comments are being submitted on behalf of the American Bar Association Sections of Antitrust Law and International Law. Sincerely, [name removed], Chair Section of Antitrust Law [name removed] M.
Impact Assessment: Fairness in Platform-to-Business Relations Obecně Definice on-line platforem je velmi široká: otázkou tedy není, které platformy do ní spadají, ale naopak, která z moderních digitálních služeb tuto definici nenaplňují. Regulace tedy zasáhne celou digitální ekonomiku.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
SME Europe: contribution to the European Commission’s inception impact assessment re fairness in platform-to-business relations ABOUT US The purpose of SME Europe a.is.b.l. (Small and Medium Entrepreneurs of Europe) is to shape EU policies in a more SME friendly way. SMEs are the power cells of the European economy as it is especially them that create sustainable jobs, growth and prosperity.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Response to EU Commission Hearing on P2B Confindustria Digitale appreciates the possibility to comment on DG CONNECT’s Inception Impact Assessment on the topic of online platform-to-business (P2B) relationships.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
11-2017 EGDF Response on the Impact Assessment of the Fairness in platform-tobusiness relations Digital distribution platforms have quickly become key players of games industry’s value chain and currently distribution platforms of digital content are quickly consolidating. Unfortunately unfair trading practices go far beyond issues related to transparency and redress.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Booking.com’s feedback on the European Commission’s inception impact assessment on fairness in platforms to businesses relations Introduction Booking.com fully supports the goals of the European Commission’s Digital Single Market Strategy (DSM).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
To whom it may concern, On behalf of the Center for Data Innovation, it is our pleasure to submit the comments in the attached file to the European Commission, in response to its recent impact assessment on “fairness in platform-to-business relations,” a study to investigate practices by online platforms—digital services that cater to two-sided markets—in their relations with other businesses.
Allegro appreciates the opportunity to contribute to the discussion on platform to business relations. The attached document highlights issues which should be taken into account in the debate and argues that self - regulation is the best approach to address issues specified in the Inception Impact Assessment.
Sky welcomes the European Commission’s approach to fairness in platform to business relations. This is an important and fundamental issue to the modern European digital economy and deserves scrutiny. Online service and businesses cannot avoid interacting with online platforms who are very often gatekeepers to European consumers online.
Position of the Slovak Alliance for Innovation Economy1 on Fairness in Platform-to-Business Relations In Bratislava, 22 November 2017 The Slovak Alliance for Innovation Economy as the largest representative of Slovak digital and innovative economy welcomes the opportunity to comment of the IIA on Fairness in Platform-toBusiness Relations.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find attached the inputs and views from IAB Spain regarding the Inception impact assessment on Fairness in platform-to-business relations. • The Commission’s evidence base doesn’t justify targeted nor prescriptive regulatory intervention: The Commission is relying on survey results from Ecorys and anecdotal evidence.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Réponse à la consultation « Fairness in platform-to-business relations » I. Contexte général Dans le cadre de sa stratégie pour un marché unique numérique, la Commission européenne travaille sur l’opportunité d’une proposition législation relative à la loyauté dans les relations entre plateformes et entreprises utilisatrices.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Madam, Dear Sir, You will find attached IMPALA's feedback on "Fairness in platform-to-business relations". IMPALA represents around 4,000 independent music companies across Europe. 99% of music companies are micro, small or medium enterprises. Together they account for 80% of all new releases, but also 80% of the sector's overall jobs and investment.
Microsoft Corporate, External & Legal Affairs Rue Montoyer 51 B-1000 Brussels Ref. Ares(2017)5714091 - 22/11/2017 Inception Impact Assessment: Fairness in platform-to-business relations Microsoft appreciates the opportunity to comment on DG CONNECT’s Inception Impact Assessment on the topic of online platform-to-business (P2B) relationships.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Ibec Principles on Online Platforms October 11, 2017 1. Ibec supports a Digital Single Market that works1 The European Commission is midway through the implementation of its digital single market (DSM) strategy2.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Platform regulation remains unjustified Diego Zuluaga, Director, EPICENTER The Commission has asked for feedback on its impact assessment of platform-to-business (P2B) relations. The IA includes a number of alternative proposals for additional intervention to regulate contractual terms and information provision in this market.
After having analysed the proposals prepared by the European Commission, ZPP wishes to present its position. When considering fairness in the business relation with platforms, adopting the regulatory option no 1 based on the soft law would be the most optimal one.
POSITION PAPER MARKENVERBAND INCEPTION IMPACT ASSESSMENT FAIRNESS IN P2B RELATIONS Markenverband would like to thank the European Commission for having the chance to give a feedback on the inception impact assessment on fairness in platform-to-business relations.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
With reference to the European Commission’s preliminary assessment on fairness in platform-to-business relations we suggest to address the following business practices which have an impact on the competition between platform providers and business users. Unbundling marketplace and payment services Nowadays, small online retailers often do not sell their products on proprietary shops, but via online marketplaces.
Re: Questions on the Inception Impact Assessment on Fairness in Platform-to-Business relations The Inception Impact Assessment (IIA) on Fairness in Platform-to-Business (P2B) relations raise a number of questions concerning the cause of the market failures, how they call for corrective measures, under what conditions these measures should be addressed through new legislation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
HOTREC thanks for the possibility to comment on the Inception Impact Assessment related to the Fairness in platform-to-business relations initiative. HOTREC, representing hotels, restaurants and cafes in Europe, welcomes the Commission’s plans to take action to balance the European Single Market regarding platform and business relationships.
FEEDBACK ON THE IMPACT ASSESSMENT ON PLATFORMS 22 NOVEMBER 2017 Title of the initiative: Fairness in platform-to-business relations Lead DG – Responsible Unit: CNECT.F.2/GROW.E.4 * * * We warmly welcome the work of the EU Commission on the practices of online platforms as well as on their legal framework.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Prescriptive EU legislative instruments and a new EU-level regulator of platforms could hit the whole Internet ecosystem because the Commission itself struggled to find a legally exclusive definition of online platforms during the 2016 review.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Inception Impact Assessment – Fairness in platform-to business relations, November 2017 Introduction We welcome this Inception Impact Assessment into fairness in platform-to-business relations. Online platforms do indeed drive innovation and growth in the digital economy. Online platforms offer an interface for millions of firms to access markets and customers enabling businesses to function in the platform economy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Society of Authors ZAiKS (ZAiKS) is a Polish organization representing artists and composers with the mission to protect their copyrights, especially in context of the rapid growth of new technologies and social media. ZAiKS is an organization set up by the authors and still managed by them.
The Wuerth Group would like to thank the European Commission for having the chance to give a feedback on the inception impact assessment on fairness in platform-to-business relations. We appreciate the research in this field as it reveals the challenges we face with the growing digital trade. It is important to solve the key problems by designing a package fit-for-purpose.
The European Commission’s Inception Impact Assessment on Fairness in platform-to-business relations Response of Spotify Spotify AB welcomes the opportunity to provide this response to the Commission’s Inception Impact Assessment on Fairness in platform-to-business relations (“IIA”).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Finnish Federation for Communications and Teleinformatics, FiCom is a co-operation organisation for the ICT industry in Finland. FiCom's members are companies and other entities that operate in the communications and teleinformatics sector in Finland. FiCom makes the following submission on assessment on regulation of the platforms.
Google appreciates the opportunity to provide feedback to the inception impact assessment (IIA) of a potential initiative from the European Commission on fairness in platform-to-business (P2B) relations. The objective of this submission is to provide Google’s perspective on the identified alleged P2B concerns as well as to outline solutions and best practices we have put in place proactively to address or overcome…
After a careful assessment of specific measures proposed by the European Commission to address fairness in platform-to-business relations, Polish Confederation Lewiatan wants to support Option 1: EU soft law action to spur industry-led intervention.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We are a Cluster of SMEs and large enterprises from Bulgaria specialized in the provision of IT, data, information and knowledge-based services. As such, the members of the Cluster have been acting on both sides of the ‘platform-to-business’ relationship - as an online platform provider and a user of other platforms’ services.
European Commission’s Forthcoming Platform Legislation Background: The European Commission (EC) is preparing a legislative proposal on fairness in platform to business relationships under the Digital Single Market Strategy. EC has published the impact assessment in end October and is collecting feedback by 22 November to decide on a degree of legislative intervention.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
European Commission’s Forthcoming Platform Legislation Background: The European Commission (EC) is preparing a legislative proposal on fairness in platform to business relationships under the Digital Single Market Strategy. EC has published the impact assessment in end October and is collecting feedback by 22 November to decide on a degree of legislative intervention.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
AMETIC response to EuropeanRef. Commission’s Ares(2017)5750547 - 24/11/2017 Forthcoming Platform Legislation AMETIC’S response to the European Commission’s Forthcoming Platform Legislation AMETIC is the Association of IT, Electronics and Digital Contents companies, which represents a sector that constitutes a real lever for sustainable economic development, which increase the competitiveness of other sectors and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Confederation of Industry of the Czech Republic appreciates the opportunity to submit feedback to the European Commission’s inception impact assessment on fairness in platform to business relations. We wanted to provide a couple of reflections on the wider consequences that this sort of platform regulation could have on the growing European platform ecosystem.
Digital development creates fundamental changes in many markets. A central role is played by digital platforms, a powerful dominating the digital economy have become business model. Thus, six of the top ten companies in the world and seven of the ten höchstbewerteten start-ups successfully with this model in the world.
Filed in German · English published by the European Commission
In response to the European Commission’s announcement of their intention to introduce new legislation to govern the relationship between platforms and businesses, the Developers Alliance surveyed over 110 European-based developers and publishers on their experiences, in an effort to gain a more robust understanding on their relationship with platforms and examine the need for regulatory intervention.
November 22, 2017 Comments of ACT | The App Association (Transparency Reg. # 7202951387754) Lighthouse Europe Avenue Adolphe Lacomblé, 59 B-1030 Brussels to The European Commission’s Directorate-General for Communications Networks, Content and Technology on its Inception Impact Assessment, “Fairness in Platform-to-Business Relations”: Ares(2017)5222469 I.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Comments by the Information Technology Industry Council on the European Union’s Impact Assessment on Fairness in Platform to Business Relations The Information Technology Industry Council (ITI), the global voice of the technology sector, appreciates the opportunity to provide a response to the European Commission’s request for feedback on the impact assessment on fairness in platform to business (P2B) relation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Unfair platform practices, often bordering on the illegally anticompetitive, harm all members of society, stifle innovation and employment and make European consumers and advertisers dependent on platforms headquartered in jurisdictions with less consumer and competition protection.
The Interactive Software Federation of Europe (ISFE) represents the European video games industry. Our membership comprises 16 major publishers and national trade associations in 17 countries throughout Europe. Our national associations in turn represent hundreds of games companies across Europe.
EDiMA feedback to the inception impact assessment on fairness in platform-to-business relations EDiMA, the European trade association representing online platforms and other innovative tech companies, continues to be an active participant in the Commission’s information-gathering exercises on P2B relations and appreciates the work on this issue.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ETTSA agrees that online platforms drive innovation and growth in the digital economy and play an important role in opening new market opportunities, notably for SMEs. The use of online platforms empowers small businesses. Access to data (particularly to the market reports provided by P2B) tends to empower small businesses, as big players have their own data analysis tools.
Dear Commissioner Gabriel, It is good that you open this debate and I am sure that wisdom shall prevail at the end. First, the European Commission must define what it means by digital platform, as this term is still vague, in evolution and subject to many debates. The Commission may refer, among others, to the definitions of platforms provided by the Body of European Regulation for Electronic Communications.
ETUC contribution for a fair platform economy Response to the European commission’s Fairness in platform-tobusiness relations initiative This Commission’s initiative aims at tackling unfair trading practices with a focus on online marketplaces (Amazon, Booking.com, etc.). It is business-oriented, with a special focus on SMEs and micro-traders using online platforms to sell their products and services.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Commission (EC) is analyzing actions to address the issues of unfair contractual clauses and trading practices identified in platform-to-business relationships, including by exploring dispute resolution, fair practices criteria and transparency.
21 November 2017 CCIA1 Comments on Inception Impact Assessment – Fairness in Platform-to-Business Relations CCIA welcomes the opportunity to comment on the Inception Impact Assessment (IIA) and values the dialogue the Commission has put into place with relevant stakeholders. We would like to stress that online platforms have become an important driver and enabler of economic activity in Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Small and medium-sized enterprises (SMEs) are the backbone of Europe's economy. They represent 99% of all businesses in the EU. In the past five years, they have created around 85% of new jobs and provided two-thirds of the total private sector employment in the EU. In the European Commission’s own words SMEs are “key to ensuring economic growth, innovation, job creation, and social integration in the EU”.
Startups on Fairness in platform-to-business relations November 21, 2017 Dear Commissioner Gabriel, Startups recognise platforms as the leading solution in the digital economy. Finally startups can spend time doing what they do best without having to be part-accountants, salesmen, IT-experts, web-developers or part-whatever.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Commission has identified a number of undesirable practices which it says threaten Europe’s successful transition to the Digital Single Market. While the Commission’s study and stakeholder consultation has found some questionable practices, fixing them will not require the more intrusive of the economic regulations which its “Reception Impact Assessment” is contemplating.
The European Commission is considering regulatory options that could be applied to the relationship between internet platforms and their businesses users. Based on consultation with stakeholders and a study commissioned from ZEW-Gutachten und Forschungsberichte, it has identified a number of undesirable practices which it says threaten Europe’s successful transition to the Digital Single Market.
ARD: 6774178922-55 ZDF: 3209361971-85 November 2017 Inception impact assessment Fairness in platform-to-business relations Context – the importance of platform in the audio-visual market ARD and ZDF, German Public Service Broadcasters, welcome the possibility to comment on the Commission’s inception impact assessment on “fairness in platformto-business relations”.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
WELL PRODUCED DOCUMENT, BASED ON THE DETAILED PREVIOUS RESEARCH. THE AIM OF THE INTERVENTION IS OF GREAT IMPORTANCE FOR THE PROPER PROGRESS OF THE DIGITAL ECONOMY. THE OBJECTIVES AND WAYS TO ATTAIN THEM ARE CLEAR AND LUCRATIVE.
Apple AppStore is a vital part of doing business online. You MUST have a website, have a Google Play app and a Apple App to do e-commerce today. OrderYOYO help small and medium size take-away restaurants do business online. 80% of Domino's orders today come from online ordering.
As mentioned in our answer to the consultation and in the Policy Brief attached, industriAll European trade union supports legislative measures providing detailed principles (option 3), establishing a “single European regulator of digital on-line services”.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.
