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 · Belgium
Declared costs: €6M+ a year · in the register since 2010
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…
AFME · filed 26 Oct 2021 · source
The Association for Financial Markets in Europe (AFME) welcomes the opportunity to provide its feedback to the European Commission on the “New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes”. Our comments on the Inception Impact Assessment have been submitted via a separate document. We would be pleased to assist with this initiative.
AFME · filed 18 Sept 2023 · source
The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commissions Proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes (FASTER). AFME strongly supports the Commissions objectives to simplify and digitise withholding tax processes within the EU.
AFME · filed 1 Apr 2021 · source
Settlement Discipline Framework AFME believes that changes to the Settlement Discipline Regime (“SDR”) should be considered the key priority of the CSDR Refit. Although the rules have not yet entered into force, there are fundamental issues with their current form. The CSDR Refit presents a perfect opportunity to make targeted amendments to the SDR to ensure its effectiveness from day one.
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.
AFME · filed 26 May 2022 · source
AFME welcomes that the European Commission proposes that Mandatory Buy-ins (MBI) will not be immediately implemented. As acknowledged in the Commission’s impact assessment, the implementation of a MBI Regime could have a disproportionately negative impact on the liquidity and competitiveness of EU capital markets.
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