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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.

ASN
ASNEF

Industry association · Spain

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
1
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €25K+ a year · in the register since 2011

ACC
6
files engaged
of 583 tracked
7
positions filed
in those 583 files
0.5
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €50K+ a year · in the register since 2014

Files both filed on (3)

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.

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.

Framework for Financial Data Access

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.

Association of Credit Card Issuers Europe (ACCIE) · filed 31 Oct 2023 · source

The Association of Credit Card Issuers in Europe represents the specialised credit card issuing industry in the EU. ACCIE welcomes the Commission's proposals for a new Framework for Financial Data Access. Our feedback can be found in the attached file.

Instant payments in euro

Association of Credit Card Issuers Europe (ACCIE) · filed 6 Apr 2021 · source

The Association of Credit Card Issuers Europe (ACCIE) is pleased to submit commentary on the roadmap on instant payments, and would like to bring to the Commission’s attention the following points: - Instant payments should be considered complementary to other payment methods, as different payment methods differ in their features, being more favourable to certain payment needs.

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.

Consumer credits

Association of Credit Card Issuers Europe (ACCIE) · filed 31 Aug 2020 · source

The Association of Credit Card Issuers Europe (ACCIE) represents the specialised European credit card issuing industry. ACCIE is pleased to submit commentary to this consultation, and fully supports the goal of the Consumer Credit Directive (CCD) to ensure high level of consumer protection in consumer credit agreements.

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.

Association of Credit Card Issuers Europe (ACCIE) · filed 2 Sept 2021 · source

The Association of Credit Card Issuers Europe (ACCIE) represents the specialized European credit card issuing industry. ACCIE is happy to submit feedback on the Commission’s proposal on the Revised Consumer Credit Directive (CCD), and wants to draw attention to the following key points regarding the creditworthiness assessment (CWA) and caps on the cost of credit: - The CWA should be proportionate to the level of…

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