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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.

AE
American Express

Company · Spain

4
files engaged
of 583 tracked
4
positions filed
in those 583 files
3
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €400K+ a year · in the register since 2015

DEC
DECO

Consumer organization · Portugal

15
files engaged
of 583 tracked
15
positions filed
in those 583 files
7.5
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2016

Files both filed on (4)

Instant payments in euro · Consumer credits · Payment services in the internal market · Payment services and electronic money services in the Internal Market

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.

Instant payments in euro

American Express · filed 7 Apr 2021 · source

American Express supports the initiatives by the Commission encourage instant payments across the EU. The design of such initiatives should consider all possible barriers to instant payments to ensure further adoption by consumers and businesses alike. A more developed instant payments infrastructure will open opportunities for payment initiation and acquiring in particular.

DECO · filed 21 Dec 2022 · source

DECO, the Portuguese Consumer Protection Association, welcomes the proposal for a Regulation on Instant payments (IPs). To achieve a widespread take up of IPs, especially from consumers, it is crucial to have a regulatory framework making them available, accessible, and secure.

Consumer credits

DECO · filed 27 Aug 2021 · source

DECO welcomes this proposal reviewing Directive 2008/48/EC on credit agreements for consumers (CCD) to better adapt it to the evolution in the market and tackle arrears. We consider that some provisions will tend to increase the level of consumer protection, reflecting the views expressed by consumer representatives: the extension of the scope to include loans below 200 and up to 100.000 EUR; the introduction of…

American Express · filed 31 Aug 2021 · source

American Express welcomes the opportunity to provide feedback on the European Commission’s proposed revision of the Consumer Credit Directive, and is supportive of the Commission’s efforts to establish a single market for credit with harmonised and strengthened consumer protection measures.

Payment services in the internal market

DECO · filed 16 Aug 2023 · source

DECO welcome this proposal. We consider the PSD2 needs to be profoundly revised especially regarding fraud, liability and redress. General comments: The proposals to address consumer/user confidence by enhancing their protection are very much welcome.

American Express · filed 1 Nov 2023 · source

American Express (Amex) welcomes the proposed Payments Services Package introduced by the European Commission (EC) in June 2023, as these proposed changes will help to foster innovation, strengthen competition, and secure safer payments. Overall, this package marks an important step towards harmonizing payment standards across the EU.

Payment services and electronic money services in the Internal Market

DECO · filed 16 Aug 2023 · source

DECO welcome this proposal. It is essential to have a thorough review of the PSD2. We agree with the conclusion of the impact assessment regarding consumers' at risk of fraud. COMMENTS Scope (Articles 1 and 2 and Recitals 13 and 68) The proposal for a Directive on licensing and supervision of payment institutions is largely based on Title II of PSD2, regarding Payment Service Providers, which only applies to payment…

American Express · filed 1 Nov 2023 · source

American Express (Amex) welcomes the proposed Payments Services Package introduced by the European Commission (EC) in June 2023, as these proposed changes will help to foster innovation, strengthen competition, and secure safer payments. Overall, this package marks an important step towards harmonizing payment standards across the EU.

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