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.
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.
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 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.
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 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).
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.
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.
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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