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Compare organizations

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.

CC
CEN and CENELEC

NGO · Belgium

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

Amending the NIS 2 Directive as regards simplification measures and alignment with the Cybersecurity Act 2 · European data governance (Data Governance Act)

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.

Amending the NIS 2 Directive as regards simplification measures and alignment with the Cybersecurity Act 2

Bitkom e.V. · filed 19 Jun 2025 · source

Position Paper June 2025 Cybersecurity Act Revision Summary The Cybersecurity Act (CSA) was introduced in 2019 as a central instrument of the European Union to strengthen the cyber security of information and communication technologies. At the time, there were no other European harmonized requirements for products concerning cybersecurity.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CEN and CENELEC · filed 11 May 2026 · source

In the Cybersecurity Act 2, CEN and CENELEC urge the Commission to: 1) Ensure that standards developed by the ESOs are maintained as the backbone of cybersecurity certification schemes. 2) Confirm that technical specifications developed by ENISA remain a last resort fallback option.

Bitkom e.V. · filed 12 May 2026 · source

Titel Ref. Ares(2026)4818540 - 12/05/2026 Revision of the EU Cybersecurity Act Position of the German digital industry on the European Commission’s proposal for a CSA-2 1 Cybersecurity Act 2 Content 1 Summary 3 2 TITLE II: THE EUROPEAN UNION AGENCY FOR CYBERSECURITY 5 TITLE III: EUROPEAN CYBERSECURITY CERTIFICATION FRAMEWORK 8 3 Article 71: Objectives and scope of the European cybersecurity certification framework 9…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bitkom e.V. · filed 12 May 2026 · source

Position Paper 2026 May NIS-2 Amendments Summary The NIS-2 Directive set the goal to establish a unified legal framework to uphold cybersecurity in critical sectors across the EU. By defining technical and methodological requirements for cybersecurity risk management measures, it aims to create a harmonised baseline level of protection.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European data governance (Data Governance Act)

CEN and CENELEC · filed 8 Feb 2021 · source

CEN and CENELEC welcome the proposal for a Regulation on European Data governance and invite the European Commission to make use of the European standardization system to support the EU policy objectives. The CEN and CENELEC feedback is enclosed to this consultation.

Bitkom e.V. · filed 8 Feb 2021 · source

If done right, the European Commission’s initial proposal on the Data Governance Act (DGA) has the potential to be an important step towards a European data economy. While previous discussions about the use of data have focused primarily on the important topic of data protection, there is an increasing awareness for the innovative potential of data, which is why we welcome that the DGA addresses all types of data…

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