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.
No ban on inducements:we are in favor of keeping the choice between commission-based and fee-based model.The current legal framework on inducements is appropriate to protect clients against potential conflicts of interest.A ban on inducements -that would leave room only for the fee-based model- will inevitably lead to an advice gap for retail clients and only a small number of wealthier investors would continue to…
ESBG supports the European Commission's view that boosting the Capital Markets Union, by strengthening the participation of retail investors in the capital markets, is an essential way to channel private finance into the economy and support the green and digital transitions.
I. Digital communication support The Czech Insurtech Association would like to express support for the European Commission's proposal regarding the prioritization of digital communication with customers within the framework of the Retail Investment Package.
I. General support to the initiative On behalf of the Czech Insurtech Association, we would like to express our strong support for the proposed Open Finance Framework (FIDA) and, specifically, the development of an Open Insurance Framework.
The European Savings and Retail Banking Group (ESBG) took note of the European Commission's proposed Regulation on the Financial Data Access Framework and its commitment to establish clear rights and obligations to manage customer data sharing in the financial sector beyond payment accounts, and to promote innovative financial products and services for users and stimulate competition in the financial sector.
The Czech Insurtech Association would like to express its gratitude for the new and modern law on liability for defective products, and is excited about the prospect of it soon becoming a reality. We are very supportive in creating a level playing field for EU operators and those non-EU based, and we welcome the introduction of clear and predictable rules facilitating legal certainty and predictability of the…
The European Savings and Retail Banking Group (ESBG) supports the protection of consumers as well as adapting liability rules to the digital age, thereby setting out a framework for excellence and trust in Artificial Intelligence. However, we understand from the proposed Directive that the presumption of a causal link in the case of fault is mainly a matter of "non-compliance of due diligence duties".
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