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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.

ASL
3
files engaged
of 583 tracked
4
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 (3)

European data governance (Data Governance Act) · Cyber Resilience Act · A high common level of cybersecurity

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.

European data governance (Data Governance Act)

Arthur's Legal, Strategies & Systems · filed 31 Jul 2020 · source

Arthur's Legal, Strategies & Systems strongly supports and endorses the initiative by the European Commission to create frameworks for common European data spaces. Technological innovation has transformed society along with every other sector of our economy and data is the main catalyst for this transformation. Digital is a need to have; not a nice to have.

Bitkom e.V. · filed 8 Feb 2021 · source

If done right, the European Commission’s initial proposal on the Data Governance Act (DGA) has the potential to be an important step towards a European data economy. While previous discussions about the use of data have focused primarily on the important topic of data protection, there is an increasing awareness for the innovative potential of data, which is why we welcome that the DGA addresses all types of data…

Cyber Resilience Act

Arthur's Legal, Strategies & Systems · filed 25 May 2022 · source

Arthur's Legal, Strategies & Systems welcomes, supports and endorses the Cyber Resilience Act initiative. In this Digital Age, digital is not a nice to have anymore but a need to have. People, organisations (public, private and other) and society at large are depending on those, while (a) not in meaningful control and (b) more and more becoming vulnerable to detrimental cyber threats, all this throughout the various…

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.

Arthur's Legal, Strategies & Systems · filed 22 Jan 2023 · source

Arthur Legal, Strategies & Systems welcomes, supports and endorses the Commission' legislative proposal to establish common, horizontal cybersecurity rules and requirements for a wide range of digital products and associated, ancillary services that are placed on the market across the European Union.

A high common level of cybersecurity

Bitkom e.V. · filed 13 Aug 2020 · source

Bitkom strongly welcomes the integration of relevant stakeholder opinions in order to streamline public and private efforts striving for an improved cybersecurity throughout the European Union (EU). That is why we would like to seize the opportunity and provide our feedback already at an early stage of the revision of the Directive (EU) 2016/1148 concerning measures for implementing an equivalent and commonly high…

Arthur's Legal, Strategies & Systems · filed 18 Mar 2021 · source

Arthur Strategies & Systems is part of Arthur’s Legal. It has handpicked experienced interdisciplinary experts to focus on ability to navigate, enable, facilitate as well as execute and systemize. Our core team consists of attorneys at law, senior legal counsels, governmental advisors, strategists, innovation, policy & standardisation experts, community & competence builders, technologists, all well-connected in the…

Bitkom e.V. · filed 18 Mar 2021 · source

As a matter of fact cyber threats have increased manifold since the adoption of the first NIS Directive. That's why we see the imperative need for a more harmonised and future-proofed European cybersecurity framework. The proposal already strikes a reasonable balance between targeted regulatory interventions and strengthening the EU's cyber-resilience holistically.

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