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ACA

ACA

Industry association · Luxembourg

2
positions filed
in the 583 files tracked
2
legislative files
of 583 tracked
0
with a full position paper
attached to a submission

Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

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Their record over time

ACA filed 2 positions between 26 Oct 2021 and 28 Jul 2023, across 2 of the 583 legislative files tracked here.

2021 · 1 filed2023 · 1 filed

What they argued

Retail investor protection rulesfiled 28 Jul 2023source

The ACA wishes to express its concern about the impact of these texts on our members. The multiple bans proposed, the many additional requirements will complicate consumers’ access to capital markets considerably, which is the exact opposite of what the European Commission is seeking to achieve with the IPM.

Filed in French · English published by the European Commission

New EU system for the avoidance of double taxation in the field of withholding taxesfiled 26 Oct 2021source

ACA welcomes the possibility to comment on this roadmap. As other actors, we believe that cross-border investment and simplified taxation should be a priority for the EU and that tax barriers to cross-border investment should be removed. However, nowadays, too often, the process to claim a refund looks more like an obstacle course than a legitimate right.

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Turns up on the same files

Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.

Showing 5 of 17.

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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.