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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.

ACC
ACCIS

Industry association · Belgium

4
files engaged
of 583 tracked
5
positions filed
in those 583 files
1
declared FTE
self-declared
1
EP accreditations
as declared to the register

Declared costs: €100K+ a year · in the register since 2009

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 (3)

Framework for Financial Data Access · Consumer credits · European single access point (ESAP): access to information in relation to financial services, capital markets and sustainability

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.

Framework for Financial Data Access

European Banking Federation · filed 2 Aug 2022 · source

The European Banking Federation (EBF) welcomes the opportunity to comment on the European Commission’s Call for Evidence on an “Open Finance Framework – enabling data sharing and third-party access in the financial sector.” A European data economy which unlocks new opportunities for customers – individuals and firms – through increased data sharing is a priority that the European banking sector welcomes in the…

ACCIS · filed 31 Oct 2023 · source

ACCIS is the voice of organisations responsibly managing data to assess the financial credibility of consumers and businesses. Established as an association in 1990, ACCIS brings together more than 50 members from countries all over Europe as well as associates and affiliates across the globe.

Consumer credits

ACCIS · filed 28 Aug 2020 · source

The Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies (CRAs) in the world. CRAs are independent organisations that securely hold data about consumers. Lenders use the information held by CRAs to assess the creditworthiness of borrowers.

ACCIS · filed 1 Sept 2021 · source

ACCIS represents the largest group of credit reference agencies in the world. ACCIS brings together 40 members across 28 European countries and 11 associate and affiliate members from all other continents. ACCIS broadly welcomes the Commission’s proposal to review the Consumer Credit Directive (CCD).

European Banking Federation · filed 2 Sept 2021 · source

The EBF and its members have extensively contributed to the consultations prior the CCD review. Regrettably, proposals for improvement on technological developments or administrative burden have not been considered. This is a missed opportunity to further integrate and modernise credit markets in Europe. A successful and efficient lending framework should consider both the needs of clients and providers.

European single access point (ESAP): access to information in relation to financial services, capital markets and sustainability

ACCIS · filed 27 Mar 2022 · source

Please find attached the comments from ACCIS. ACCIS is the voice of organisations responsibly managing data to assess the financial credibility of consumers and businesses. Established as an association in 1990, ACCIS brings together more than 40 members from countries all over Europe as well as associates and affiliates across the globe.

European Banking Federation · filed 29 Mar 2022 · source

EBF Key Messages on ESAP The EBF welcomes and supports the proposal to establish ESAP to provide investors with a common database for financial and sustainability information that EU companies are required to publish pursuant to EU regulation.

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