Side by side
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.
Public authority · France
Industry association · Germany
Declared costs: €2.8M+ a year · in the register since 2008
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.
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.
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
German Insurance Association (GDV) · filed 31 Aug 2021 · source
The German insurance industry welcomes the developments at the European level, the introduction of a European identity scheme (EUid) in combination with the proposed amendments of the Regulation (EU) No 910/2014 (eIDAS) by the European Commission and supports the approach to establish an EU-wide ecosystem on digital identities in form of a European identity scheme (EUid).
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
German Insurance Association (GDV) · filed 10 Dec 2020 · source
The German Insurance industry welcomes the EC’s efforts to provide practical solutions for the transfer of personal data to third countries. While the draft implementation act and the updated SCCs are a great step forward, certain adjustments appear necessary and sensible.
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