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 · Finland
Declared costs: €600K+ 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…
Finance Finland · filed 26 Oct 2021 · source
Finance Finland welcomes the European Commission’s initiative to introduce a common EU-wide system for withholding tax on dividend payments. Complicated and different withholding tax processes form a substantial barrier to cross-border investments within the EU and it is important that withholding tax processes should be harmonized.
Finance Finland · filed 25 May 2022 · source
For the most part, the amendment proposals related to settlement discipline benefit the sector because they harmonise the operating principles of market participants from different markets. They also promote the simultaneity of securities trade and related payments, which will improve investor protection and reduce the risks of market participants.
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.
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