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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.

BFR
2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
AE
ACI EUROPE

Industry association · Belgium

10
files engaged
of 583 tracked
10
positions filed
in those 583 files
10.5
declared FTE
self-declared
5
EP accreditations
as declared to the register

Declared costs: €900K+ a year · in the register since 2010

Files both filed on (2)

Update of common rules for the allocation of slots at European Union airports · Review of EU rules on the allocation of slots at Union airports

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.

Update of common rules for the allocation of slots at European Union airports

ACI EUROPE · filed 23 May 2022 · source

Airports welcome the opportunity to provide comments on the European Commission’s planned update of the Slot Regulation so as to maintain relief measures, as appropriate, due to the COVID-19 pandemic and the Russian invasion of Ukraine. ACI EUROPE has consistently, over the period of the COVID-19 crisis, supported a progressive reinstatement of airport slot usage requirements, as the market stabilizes and recovers.

Bundesministerium für Digitales und Verkehr · filed 24 May 2022 · source

The Federal Ministry of Digital and Transport warmly welcomes the European Commission’s initiative to design the EU Slot Regulation in a crisis-proof manner in the light of the impact of the Covid-19 pandemic and Russia’s invasion in Ukraine.

Filed in German · English published by the European Commission

Review of EU rules on the allocation of slots at Union airports

Bundesministerium für Digitales und Verkehr · filed 21 Nov 2022 · source

The Federal Government of the Federal Republic of Germany welcomes the opportunity to respond to the public consultation "Public consultation: Allocation of EU airport slots review of rules as follows (please find attached an informal courtesy translation into English): Comments from the Federal Government of the Federal Republic of Germany in the context of the public consultation on the allocation of slots at EU…

Filed in German · English published by the European Commission

ACI EUROPE · filed 21 Nov 2022 · source

ACI EUROPE, representing over 500 airports in 55 countries, supports the European Commission's initiative to review the Slot Regulation. ACI EUROPE believes that the following elements should form part of a revised Regulation: - Greater transparency in the slot allocation process; - More scope to ensure that slot allocation takes into account the economic and connectivity strategies of airports and the related needs…

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