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 · Austria
Trade union · Belgium
Declared costs: €1.8M+ a year · in the register since 2008
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.
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.
WSBI-ESBG · filed 31 May 2022 · source
No ban on inducements:we are in favor of keeping the choice between commission-based and fee-based model.The current legal framework on inducements is appropriate to protect clients against potential conflicts of interest.A ban on inducements -that would leave room only for the fee-based model- will inevitably lead to an advice gap for retail clients and only a small number of wealthier investors would continue to…
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.
WSBI-ESBG · filed 4 Aug 2023 · source
ESBG supports the European Commission's view that boosting the Capital Markets Union, by strengthening the participation of retail investors in the capital markets, is an essential way to channel private finance into the economy and support the green and digital transitions.
WSBI-ESBG · filed 23 Oct 2023 · 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.
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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