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 Savings and Retail Banking Group (ESBG) took note of the European Commission's proposed Regulation on the Financial Data Access Framework and its commitment to establish clear rights and obligations to manage customer data sharing in the financial sector beyond payment accounts, and to promote innovative financial products and services for users and stimulate competition in the financial sector.
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.
Please find attached the European Savings and Retail Banking Group's response to this public consultation. ESBG represents the locally focused European banking sector, helping savings and retail banks in 21 European countries strengthen their unique approach that focuses on providing service to local communities and boosting SMEs.
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).
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.
ESBG welcomes the opportunity to comment on the European Commission’s proposal for a Regulation establishing a European single access point (ESAP). The availability of quality, comparable, reliable and public ESG data is currently rather limited and insufficient to meet rising expectations and new legal requirements set to take effect soon.
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