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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

EMA
Electronic Money Association

Industry association · Belgium

9
files engaged
of 583 tracked
11
positions filed
in those 583 files
3.3
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €300K+ a year · in the register since 2012

Files both filed on (3)

Instant payments in euro · 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.

Electronic Money Association · filed 5 Jan 2023 · source

The EMA welcomes the Commissions proposals to improve the supply of instant payments across Europe, and tackle the key issues that have hampered the uptake of instant payment in euro. We share the Commissions view that SEPA instant payments have the capacity to form the foundations to support the EU retail payments strategy.

Payment services in the internal market

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.

Electronic Money Association · filed 1 Nov 2023 · source

The Electronic Money Association (EMA), established in 2001, is the trade body for European and UK Crypto Assets Providers (CASPs), Payment Institutions (PIs), E-Money Institutions (EMIs), and Credit Institutions (CIs) providing innovative payments.

Payment services and electronic money services in the Internal Market

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.

Electronic Money Association · filed 1 Nov 2023 · source

The Electronic Money Association (EMA), established in 2001, is the trade body for European and UK Crypto Assets Providers (CASPs), Payment Institutions (PIs), E-Money Institutions (EMIs), and Credit Institutions (CIs) providing innovative payments.

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