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.
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.
The European Savings and Retail Banking Group (ESBG) took note of the European Commission's proposed Regulation on the Financial Data Access Framework and its commitment to establish clear rights and obligations to manage customer data sharing in the financial sector beyond payment accounts, and to promote innovative financial products and services for users and stimulate competition in the financial sector.
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.
ESBG and its Members fully support efforts to increase the uptake of SCTInst and share the view that it could facilitate stronger and more integrated homegrown pan-EU payment solutions. The EC should foster an environment that enables the uptake of instant payments, e.g.
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.
Please find attached the European Savings and Retail Banking Group's response to this public consultation. ESBG represents the locally focused European banking sector, helping savings and retail banks in 21 European countries strengthen their unique approach that focuses on providing service to local communities and boosting SMEs.
“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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