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.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
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.
The EWL recognises the significance of the Anti-Trafficking Directive as a core pillar in the EU’s fight against all forms of violence against women and girls, recognising that this is a highly gendered crime given that the majority of victims are victims of trafficking for sexual exploitation (79%), and that the vast majority of those victims are women and girls (according to the UN 71% of victims are women).
The European Womens Lobby welcomes some elements made in this proposal of update of the Anti-Trafficking Directive and especially the provisions aiming at improving the identification of victims of trafficking, the liability of legal persons, the data collection and the mandatory criminalisation of the knowing use of an act provided by a victim of trafficking since very few member states have implemented this…
The Alliance Nordic Model includes over 45 associations, initiatives, numerous individuals from civil society and survivors of prostitution from Germany, Austria and Switzerland. Our alliance partners have many years of practical experience in working with prostitutes and outstanding expertise on the consequences of legalised prostitution in Germany.
Dear Sir or Madam, the Nordic Model Alliance is an alliance of over 45 national civil society associations, networks and initiatives, as well as many active individuals in Germany. Gender-based violence is deeply rooted in the structures, norms, social and cultural values of the prostitution system. As in other areas of society, it is both a cause and a consequence of unequal power relations.
Filed in German · English published by the European Commission
The European Women’s Lobby (EWL) suggests that harmful practices against women and girls should be understood in a broader way and include all kinds of violence against women and girls, whether it is because of the new forms of violence that emerged through the era of digitalisation and that was not necessarily foreseen in the Istanbul Convention - e.g.
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