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 · Germany
Declared costs: €100K+ a year · in the register since 2015
Trade union · Belgium
Declared costs: €4M+ a year · in the register since 2008
Retail investor protection rules · Transparency and integrity of Environmental, Social and Governance (ESG) rating activities · European single access point (ESAP): access to information in relation to financial services, capital markets and sustainability
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.
Association of German Public Insurers · filed 9 Aug 2023 · source
The fundamental aim of the EU Retail Investment Strategy (RIS), namely strengthening retail investors participation in Europes capital markets, is to be supported. The German Association of Public Insurers (VöV) therefore appreciates the opportunity for consultation and is ready to lend constructive support to the implementation process.
European Banking Federation · filed 28 Aug 2023 · source
The EBF supports the objective of the RIS to enhance retail investor safe participation in EU capital markets. The EBF appreciates proposed elements like digital-by-default communication, efforts to streamline disclosures and further financial literacy, but expresses substantial concern over the complexity, unclear implementation pathways, and negative impacts that far-reaching measures may produce without being…
Association of German Public Insurers · filed 1 Sept 2023 · source
The Association of Public Insurers welcomes the European Commission’s initiative to establish a legal framework for environmental, social and governance (ESG) ratings. As the second largest German primary insurer with a strong regional presence, the Group strongly supports the objective of a more sustainable economy.
Filed in German · English published by the European Commission
European Banking Federation · filed 1 Sept 2023 · source
The European Banking Federation welcomes the opportunity to respond to the Have Your Say on the European Commission's proposal for a Regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities. We share our views in relation to the proposal in attachment.
Association of German Public Insurers · filed 15 Jan 2021 · source
The Association of German Public Insurers (www.voev.de) welcomes the initiative of the European Commission to create an EU-wide platform for company information, in particular for sustainability data. So far, the availability of high quality, reliable and comparable data is insufficient to comply with the increasing expectations and new regulatory requirements in the realm of sustainable finance.
Association of German Public Insurers · filed 1 Mar 2022 · source
The Association of German Public Insurers strongly welcomes the European Commission's initiative to strengthen the availability of sustainability data. The Sustainable Finance Disclosure Regulation (SFDR) requires insurers to disclose the sustainability data of their investments. The Taxonomy Regulation, specifically Art. 8, requires disclosure of additional sustainability indicators.
European Banking Federation · filed 29 Mar 2022 · source
EBF Key Messages on ESAP The EBF welcomes and supports the proposal to establish ESAP to provide investors with a common database for financial and sustainability information that EU companies are required to publish pursuant to EU regulation.
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