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
Trade union · Belgium
Declared costs: €1.8M+ a year · in the register since 2008
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.
WSBI-ESBG · filed 31 May 2022 · source
No ban on inducements:we are in favor of keeping the choice between commission-based and fee-based model.The current legal framework on inducements is appropriate to protect clients against potential conflicts of interest.A ban on inducements -that would leave room only for the fee-based model- will inevitably lead to an advice gap for retail clients and only a small number of wealthier investors would continue to…
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
WSBI-ESBG · filed 4 Aug 2023 · source
ESBG supports the European Commission's view that boosting the Capital Markets Union, by strengthening the participation of retail investors in the capital markets, is an essential way to channel private finance into the economy and support the green and digital transitions.
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.
WSBI-ESBG · filed 13 Sept 2023 · source
European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide feedback to the European Commission's consultation on the "New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes". ESBG is pleased to provide the comments in the attached document.
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