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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

WE
WSBI-ESBG

Trade union · Belgium

36
files engaged
of 583 tracked
38
positions filed
in those 583 files
11.5
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €1.8M+ a year · in the register since 2008

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

WSBI-ESBG · filed 23 Oct 2023 · 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.

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.

Instant payments in euro

WSBI-ESBG · filed 7 Apr 2021 · source

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.

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

WSBI-ESBG · filed 30 Aug 2021 · source

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.

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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