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.
CFA Institute welcomes the opportunity to provide its views on the proposed changes to the investment research rules under the MiFID II regulatory framework. CFA Institute has some reservation about the generalized relaxation approach and, in particular, the proposal of exempting unbundling of investment research for small and medium caps, including fixed-income research.
Deutsche Börse Group (DBG) welcomes the proposed Delegated Act on SME Research. We share the Commission’s view that exempting small and mid-cap enterprises (SMEs) from the unbundling rule will contribute to an increase of research coverage for those. Moreover, we agree with the definition of SMEs (market capitalisation of < EUR 1 bn over 12 months period).
Currently, investor protection rules are set out in a number of sector specific legislative instruments at EU level, while general consumer protection frameworks remain under national rules. In order to better reflect the variety of issues across member states, it would be useful to target especially retail investors responses to the consultation. Could this be done through the traditional consultation process?
Deutsche Börse Group appreciates the opportunity to provide feedback on the roadmap for a retail investment strategy for the EU as part of the CMU Action Plan. Over the course of the last years, in particular in 2020, we have seen positive developments in EU retail participation as well as a change in investor behavior.
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