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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.

CND
Conseil National du Numérique

Public authority · France

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)

European Digital Identity framework · Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

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.

European Digital Identity framework

Conseil National du Numérique · filed 28 Aug 2020 · source

The National Digital Council published on 15 June 2020 a report entitled Digital Identities. Core elements of digital citizenship. The report follows a letter of referral from the Secretary of State for Digital Affairs in July 2019. It contains 35 recommendations aimed at guiding the government in the development of French digital identities.

Filed in French · English published by the European Commission

Bitkom e.V. · filed 2 Sept 2021 · source

Bitkom welcomes the Commission’s draft, as it is another important building block for secure digital identities and trust services in the European Union. Europe’s digital sovereignty will be strengthened by establishing digital identities and allowing them to be used independently by EU citizens across the EU. Bitkom thanked for the opportunity to comment in the consultation process. Please find attached the opinion.

Filed in German · English published by the European Commission

Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

Conseil National du Numérique · filed 10 Dec 2020 · source

On 12 November 2020, the Commission consulted the Implementing Decision aimed at ensuring compliance with the requirements of Regulation (EU) 2016/679 as regards the transfer of personal data to a third country [1]. This is in response to the judgment of the Court of Justice of the European Union (CJEU) Schrems II [2] of 20 July 2020, which invalidates the so-called Privacy Shield Agreement [3].

Filed in French · English published by the European Commission

Bitkom e.V. · filed 10 Dec 2020 · source

We welcome the European Commission public consultation period on the Draft implementing decision and its Annex to discuss the standard contractual clauses (SCCs) for transferring personal data to non-EU countries as this is an important issue and an opportunity for stakeholders across all industries to provide input. Please find attached our detailed Position Paper.

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