ClubPSCo welcomes the Commission's proposal to ensure the standardisation and security of electronic archiving services. However, ClubPSCo hopes that the new standard CEN/TS 18170:2025 will be referenced in this act, replacing all the other standards mentioned in the proposed implementing act. See detailed feedback attached.
CLU
ClubPSCo
NGO · France
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
3
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
ClubPSCo filed 3 positions between 12 May 2025 and 30 Sept 2025, across 3 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
ClubPSCo members thank the European Commission for the excellent work carried out on the new regulations. These implementing acts will be very effective in improving safety and interoperability and developing the internal market on a fair and competitive basis. ClubPSCo members nevertheless propose the following few modifications.
The obligation to notify supervisory bodies the changes should be limited to relevant changes, meaning with an objective impact on the risk analysis, or creating a real impact to end users. ClubPSCo has experimented such procedures with French ANSSI for more than a decade, and it appears to be realistic, strong enough and practicable for QTSP.
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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.
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