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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.

BLA
BlackBerry

Company · Canada

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
0.1
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €25K+ a year · in the register since 2018

BV
Bitkom e.V.

Industry association · Germany

53
files engaged
of 583 tracked
61
positions filed
in those 583 files
7
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €1M+ a year · in the register since 2008

Files both filed on (2)

Cyber Resilience Act · Type approval of motor vehicles regarding access to in-vehicle generated data

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.

Cyber Resilience Act

Bitkom e.V. · filed 20 Jan 2023 · source

Bitkom appreciates the opportunity to provide feedback on the Commissions proposal for a Cyber Resilience Act. Please find our position paper attached. We welcome the proposal to create a more efficient legal framework to improve cybersecurity in Europe. Nevertheless, some important aspects should be optimized and clarified during the legislative process.

BlackBerry · filed 23 Jan 2023 · source

Dear European Commission, BlackBerry is a global leader in cybersecurity. For close to 40 years, BlackBerry has invented and built trusted security solutions to give people, governments, and businesses the ability to stay secure, mobile and productive. We have reviewed the draft cyber-resilience act and provide comments in the attached.

Type approval of motor vehicles regarding access to in-vehicle generated data

BlackBerry · filed 2 Aug 2022 · source

This consultation should seek to identify means to align the horizontal and sectorial EU with the UNECE Regulations 155 and 156 on cyber security and software update management system. Specifically, directives 2014/53/EU and (EU) 2019/2144 should fully align with the network and cyber security provisions laid down by the aforementioned UN vehicle regulations.

Bitkom e.V. · filed 2 Aug 2022 · source

Bitkom welcomes the EU Commission's initiative with the aim to facilitate the use of data for a smarter, safer, and sustainable mobility ecosystem. However, we would like to also underline that relying on market principles will be key to fostering the enormous potential of data-driven solutions in the field of mobility.

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