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
Trade union · Belgium
Declared costs: €4M+ a year · in the register since 2008
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…
European Banking Federation · filed 18 Sept 2023 · source
The EBF welcomes efforts at simplification and digitisation of withholding tax processes within the Union. Slow and complex withholding tax reclaim processes remain barriers to efficient investment. A simple, swift, and safe system would encourage intra-union and foreign investment. Nevertheless, the proposed rules remain complex and would require significant due diligence and reporting.
European Banking Federation · filed 3 Apr 2021 · source
EBF Members welcome the possibility to provide feedback on the review of EU rules to improve the cross-border provision of settlement services in the EU, which they see as a key component of the 2020 Capital Markets Union Action Plan. In this context, EBF members are of the view that a top priority level should be given to the review of the settlement discipline framework.
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.
European Banking Federation · filed 26 May 2022 · source
For the further details, please see the full text attached. The EBF welcomes the initiative of the European Commission (EC) to propose changes to CSDR with a view to enhance the efficiency of EU’s settlement markets. In particular, the EBF welcomes the decision not to implement MBIs immediately and to prioritize the use of cash penalties.
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