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Compare organizations

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.

AFP
AFPA

Industry association · Austria

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
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 (2)

Retail investor protection rules · Framework for Financial Data Access

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.

Retail investor protection rules

AFPA · filed 31 Jul 2023 · source

For further inquiries: [name removed], Chairman Austrian Financial and Insurance Professionals Association, AFPA Albertgasse 35/1, 1080 Wien tel: [phone removed] email: [email removed] www.afpa.at AFPA, founded in 2011, is the independent industry association of Austria's self-employed insurance intermediaries and financial advisors and a member of the European industry association FECIF, based in Brussels.

European Banking Federation · filed 28 Aug 2023 · source

The EBF supports the objective of the RIS to enhance retail investor safe participation in EU capital markets. The EBF appreciates proposed elements like digital-by-default communication, efforts to streamline disclosures and further financial literacy, but expresses substantial concern over the complexity, unclear implementation pathways, and negative impacts that far-reaching measures may produce without being…

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…

AFPA · filed 28 Oct 2023 · source

We would like to share our feedback on the consultation on the Open Finance Framework. We have included our comments in the separate attachment. Thank you very much for your consideration. We are happy to engage in a dialogue and provide further input and support.

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