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 · United States
Declared costs: €25K+ a year · in the register since 2016
Industry association · Italy
Declared costs: €1.8M+ a year · in the register since 2013
New EU system for the avoidance of double taxation in the field of withholding taxes · Settlement discipline, cross-border provision of services, supervisory cooperation, provision of banking-type ancillary services and requirements for third-country central securities depositories
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 Global Custodians · filed 26 Oct 2021 · source
The Association of Global Custodians welcomes the Commission's initiative to improve withholding tax procedures within the EU. As detailed in the attached letter, we believe a well-functioning relief at source system must be the primary solution (based on standardized documentation, investor self-certification, and electronic data transmission), supplemented by simplified and streamlined reclaim procedures and…
Italian Banking Association · filed 18 Sept 2023 · source
1. We agree on the desirability of a common, standardised EU-wide system of exemptions and reductions of withholding taxes on cross-border income flows. This would reduce the impact of double taxation and would be a significant improvement on the current situation where several procedures are still based on paper documents, resulting in the need to apply for different originals, with long lead times and inconsistent…
Association of Global Custodians · filed 26 May 2022 · source
The Association of Global Custodians (AGC) welcomes the European Commission’s Proposal for changes to CSDR. The Commission’s Proposal introduces some important and necessary changes - but it can still be improved in some areas.
Italian Banking Association · filed 26 May 2022 · source
In terms of entities subject to the settlement penalties, as we elaborated in our Response to the Commissions’ consultation on a Possible Review of the CSDR (run between December 2020 and February 2021), we continue to suggest the removal of CCPs’ responsibility on the collection and distribution of penalties to clearing members affected by the settlement fails, moving this responsibility on CSDs for both cleared…
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