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Compare organizations

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.

ACA
ACA

Industry association · Luxembourg

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
EBF
European Banking Federation

Trade union · Belgium

48
files engaged
of 583 tracked
56
positions filed
in those 583 files
12.9
declared FTE
self-declared
12
EP accreditations
as declared to the register

Declared costs: €4M+ a year · in the register since 2008

Files both filed on (2)

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.

What each said, in their own words

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.

Retail investor protection rules

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

European Banking Federation · filed 28 Aug 2023 · source

The EBF supports the objective of the RIS to enhance retail investor safe participation in EU capital markets. The EBF appreciates proposed elements like digital-by-default communication, efforts to streamline disclosures and further financial literacy, but expresses substantial concern over the complexity, unclear implementation pathways, and negative impacts that far-reaching measures may produce without being…

New EU system for the avoidance of double taxation in the field of withholding taxes

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.

European Banking Federation · filed 18 Sept 2023 · source

The EBF welcomes efforts at simplification and digitisation of withholding tax processes within the Union. Slow and complex withholding tax reclaim processes remain barriers to efficient investment. A simple, swift, and safe system would encourage intra-union and foreign investment. Nevertheless, the proposed rules remain complex and would require significant due diligence and reporting.

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