Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
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.
Industry association · Luxembourg
Industry association · Italy
Declared costs: €1.8M+ a year · in the register since 2013
Retail investor protection rules · New EU system for the avoidance of double taxation in the field of withholding taxes
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
ACA · filed 28 Jul 2023 · source
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
Italian Banking Association · filed 9 Aug 2023 · source
ABI supports the creation of the CMU and its objectives, including that to facilitate retail investor participation in the EU capital market. The Retail Investment Strategy, however, proposes regulatory changes that would have a significant impact on the financial industry, adversely affecting the development of the EU capital market.
ACA · filed 26 Oct 2021 · source
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.
Italian Banking Association · filed 18 Sept 2023 · source
1. We agree on the desirability of a common, standardised EU-wide system of exemptions and reductions of withholding taxes on cross-border income flows. This would reduce the impact of double taxation and would be a significant improvement on the current situation where several procedures are still based on paper documents, resulting in the need to apply for different originals, with long lead times and inconsistent…
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