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CLU

ClubPSCo

NGO · France

3
positions filed
in the 326 files tracked
3
legislative files
of 326 tracked
2
with a full position paper
attached to a submission

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

Qualified electronic archiving servicesfiled 29 Sept 2025PDFsource

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.

Qualified certificates for electronic signatures and electronic sealsfiled 12 May 2025source

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.

General requirements for qualified trust service providersfiled 30 Sept 2025PDFsource

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.

Showing 5 of 10.

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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.