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.
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.
EDF welcomes the opening of the procedure to establish a European Disability Card. This idea emerged from the disability movement and has been a high priority ever since our Freedom of Movement campaign in 2011. The pilot project showed its feasibility and the opportunities it can bring.
1. Overview Alzheimer Europe supports the introduction of a European Disability Card. We believe that such a measure has the potential to address some of the barriers faced by persons with disabilities across Europe, including persons living with an invisible disability, such as dementia.
First of all, we would like to underline that our initial reception of the proposal is very positive. The proposal will result in binding legislation for both Cards. For many years EDF has campaigned for the European Disability Card, and we, and our extensive membership took part in the policy development process till now; most priorities we highlighted have been included in the proposal.
The European Disability Forum (EDF) recognises the importance of adoption and application of conflict of laws treaties as a means to provide legal certainty, avoid gaps and promote the uniform application of substantive international law including in the EU. However, conflict of laws legislation should not lead to human rights violations of the person impacted by the measures at stake.
Alzheimer Europe broadly welcomes the Commissions proposals in relation to cross border arrangements for adults in need of legal support, as well as the proposal for Member States to join the HCCH 2000 Protection of Adults Convention.
The European Disability Forum (EDF) is extremely concerned that the proposed Regulation on protection of adults does not comply with the obligations of the EU and all its Member States under the United Nations Convention on the rights of persons with disabilities (CRPD), and is generally in breach with the fundamental rights of equality and autonomy applicable to every EU citizen.
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