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.
ClubPSCo
NGO · France
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), 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 326 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.
- European Banking Federation · 3 files in common
- Association of German Banks · 3 files in common
- Assocertificatori · 3 files in common
- Bitkom e.V. · 2 files in common
- European Signature Dialog · 2 files in common
Showing 5 of 10.
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