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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.

APC
Alliance pour la Confiance Numérique

Industry association · France

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
BV
Bitkom e.V.

Industry association · Germany

53
files engaged
of 583 tracked
61
positions filed
in those 583 files
7
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €1M+ a year · in the register since 2008

Files both filed on (2)

Cyber Resilience Act · Establishment of European Business Wallets

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.

Cyber Resilience Act

Bitkom e.V. · filed 20 Jan 2023 · source

Bitkom appreciates the opportunity to provide feedback on the Commissions proposal for a Cyber Resilience Act. Please find our position paper attached. We welcome the proposal to create a more efficient legal framework to improve cybersecurity in Europe. Nevertheless, some important aspects should be optimized and clarified during the legislative process.

Alliance pour la Confiance Numérique · filed 23 Jan 2023 · source

The Alliance for Digital Trust (ACN), with more than 100 members, represents French companies (global leaders, SMEs and mid-caps) in the digital trust sector, in particular cybersecurity, digital confidentiality and trustworthy Artificial Intelligence. The NCA has for many years been calling for public authorities to rely on the importance of digital trust in an increasingly connected world.

Filed in French · English published by the European Commission

Establishment of European Business Wallets

Bitkom e.V. · filed 11 Jun 2025 · source

In the attached position paper, Bitkom highlights the key challenges organizations face in B2B and B2G contexts and to some extent in B2C, B2M and B2E and outlines essential use cases alongside technical and legal requirements to be integrated into the forthcoming EU legislation on the EUBW.

Alliance pour la Confiance Numérique · filed 12 Jun 2025 · source

LACN (Alliance for Digital Confidence) welcomes the work undertaken by the European Commission to set up a European Business Portfolio project. The French digital entity sector considers that this initiative is a useful complement to the building currently being built on the digital entity of legal persons, and that the autonomous scope of each of these projects must ensure that any interaction between them is…

Filed in French · English published by the European Commission

Bitkom e.V. · filed 6 May 2026 · source

Bitkom supports the European Business Wallet in principle as an important element of a European trust infrastructure for digital business and administrative processes. However, against the backdrop of the current negotiations on the proposed regulation and the recently discussed amendments, Bitkom sees a need for targeted improvements: Clear and swiftly adopted implementing acts are required, along with ambitious…

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