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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

GIG
GISAD i.G.

Other · Germany

25
files engaged
of 583 tracked
27
positions filed
in those 583 files
1
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €10K+ a year · in the register since 2021

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

GISAD i.G. · filed 25 May 2022 · source

>>Challenges: GISAD welcomes the EU Commission's intention for a cyber resilience law. However, it is doubted that even option 5 will achieve the desired purpose. Politicians always want to regulate something after the fact, when a wrong development has been identified.

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

GISAD i.G. · filed 17 Jun 2022 · source

Challenges: GISAD welcomes the EU Commission's initiative to regulate access to vehicle data. Appropriate is option 3, to impose legal requirements in addition to prescribing a list of the data. The customer can remain largely anonymous if the state of the art is exhausted. For example, 1,000 IP addresses can be made available per user, which are used randomly, as described in patent application DE102017005550 (A1).

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.

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