Side by side
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.
Industry association · Spain
Declared costs: €25K+ a year · in the register since 2011
Industry association · Italy
Declared costs: €25K+ a year · in the register since 2020
Framework for Financial Data Access · Instant payments in euro · Consumer credits
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
ASNEF · filed 27 Oct 2023 · source
Please find attached the comments from ASNEF, the Spanish Finance Houses Association, duly registered in the Transparency Registry with nº 11218815591-29, with regards to the European Commission's proposed Regulation on the Financial Data Access Framework.
ANASF · filed 30 Oct 2023 · source
We are basically satisfied with the proposal for a regulation presented by the Commission. However, we consider it appropriate to specify in the Regulation, in a clear manner, that is permissible the compensation for data retention by the data holders, and that it is not instead permissible to provide for a compensation for the sale of customer data by the data holder to an end-user: customers data are in fact the…
ANASF · filed 20 Dec 2022 · source
Dear Commission, in accepting the invitation in the consultation paper on the Proposal for a regulation of the European Parliament and of the Council on amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in euro, ANASF - National Association of Financial Advisors intends to express the following remarks.
ASNEF · filed 27 Dec 2022 · source
Por la presente se adjuntan los comentarios de ASNEF (nº de Registro de Transparencia 11218815591-29) relativos a la propuesta de Reglamento sobre transferencias inmediatas y, en concreto, en relación con los Artículos 5 quáter, apartado 1 y 5 quinquies, apartado 3.
ANASF · filed 30 Aug 2021 · source
Anasf shares the possibility, identified in recital 43 and in Article 16 of the European Commission’s proposal for a Directive, to provide advice in the form of personalised recommendations in combination with the granting or intermediation of credit, provided that it is clear to the consumer what the advice service consists of, precisely because of the importance of this service in other areas.
ASNEF · filed 2 Sept 2021 · source
“The Spanish Finance Houses Association (ASNEF), the voice of the Spanish specialized consumer credit providers welcomes the opportunity to contribute with it´s comments to the European Commission’s proposal for a Consumer Credit Directive (CCD). Please find enclosed our comments on the Directive proposal.
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