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
Consumer organization · Portugal
Declared costs: not declared · in the register since 2016
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.
DECO · filed 16 Aug 2023 · source
DECO welcome this proposal. General comments: Acknowledging the objective of promotion of a data driven economy, it is important that there is a regulatory framework to establish the rules by which data sharing happens. This is particularly relevant for financial data as it entails sensitive information of natural persons and firms.
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.
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.
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.
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…
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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