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
Industry association · Germany
Declared costs: €2.8M+ 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.
German Insurance Association (GDV) · filed 25 May 2022 · source
We appreciate the opportunity to comment on the call for evidence. While we consider targeted modifications of existing legislation to be appropriate in some points, we are convinced that the current regulation on insurance-based investment products has, for the most part, worked well in practice.
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.
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.
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.
2 organizations on one sheet: every file each filed on, their register declarations, and a working link to each submission. Free: we ask for your name and email, and PolicySpeak may contact you about the product (privacy policy). The per-file record stays downloadable without signing up on each file’s page.