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 · Belgium
Declared costs: €100K+ a year · in the register since 2009
Industry association · Germany
Declared costs: €2.8M+ a year · in the register since 2008
Framework for Financial Data Access · Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries · 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.
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.
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.
German Insurance Association (GDV) · filed 31 Oct 2023 · source
The German insurance industry generally supports the European considerations to promote a data-driven financial system. With the presented legislative proposal on a framework for access to financial data ("FiDA"), retail and corporate customers are to be given more creative scope in the use of their financial data.
ACCIS · filed 10 Dec 2020 · source
Established in Dublin in 1990, the Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies in the world. ACCIS brings together 42 members across 28 European countries and 10 associate and affiliate members from all other continents. Please find our feedback on this consultation in the attached PDF document. Thank you for your attention.
German Insurance Association (GDV) · filed 10 Dec 2020 · source
The German Insurance industry welcomes the EC’s efforts to provide practical solutions for the transfer of personal data to third countries. While the draft implementation act and the updated SCCs are a great step forward, certain adjustments appear necessary and sensible.
German Insurance Association (GDV) · filed 15 Jan 2021 · source
The German Insurance Association (GDV) welcomes the European Commission’s initiative to establish a European Single Access Point (ESAP) for financial and non-financial information publicly disclosed by companies.
German Insurance Association (GDV) · filed 22 Mar 2022 · source
The German Insurance Association GDV greatly welcomes that ESAP will be established by no later than 31 December 2024 and will provide centralized access to publicly available financial and sustainability information of relevance to investors on capital markets and necessary to comply with sustainability reporting obligations.
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.
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