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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.

DE
Danish Energy

Industry association · Denmark

8
files engaged
of 583 tracked
10
positions filed
in those 583 files
4.8
declared FTE
self-declared
7
EP accreditations
as declared to the register

Declared costs: €500K+ a year · in the register since 2008

IS
Iberdrola S.A.

Company · Spain

41
files engaged
of 583 tracked
50
positions filed
in those 583 files
3.2
declared FTE
self-declared
5
EP accreditations
as declared to the register

Declared costs: €700K+ a year · in the register since 2012

Files both filed on (8)

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Energy Efficiency Directive · Revision of the Energy Tax Directive · CO2 emission standards for cars and vans · Gas and hydrogen markets regulation · Deployment of alternative fuels infrastructure · Sustainable aviation fuels (ReFuelEU Aviation Initiative) · Gas and hydrogen markets directive (common rules)

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.

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport

Iberdrola S.A. · filed 24 Nov 2020 · source

Decarbonisation price signals and a level playing field for all the available energy supply options are essential to tackle emissions and increase efficiency, both for consumers and emitters. The price of products must internalise their total environmental cost so those with a lower carbon footprint become more competitive.

Danish Energy · filed 26 Nov 2020 · source

Danish Energy highly welcome the opportunity to comment on the European Commission’s Roadmap as part of the EU Emissions Trading System (ETS) review process. In light of the EU target of climate neutrality and the Commission’s proposal to increase the 2030 reduction target to at least -55%, Danish Energy supports reviewing and strengthening the EU ETS in order to ensure the ETS remains a primary driver of Europe’s…

Danish Energy · filed 8 Nov 2021 · source

This document comprise Danish Energy’s updated positions on: 1. The ETS-directive and the Market Stability Reserve (MRS) 2. The Carbon Border Adjustment Mechanism (CBAM) Generally, we find that the proposed revision of the ETS-directive is very positive.

Iberdrola S.A. · filed 8 Nov 2021 · source

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Energy Efficiency Directive

Danish Energy · filed 21 Sept 2020 · source

Please find the attached paper for our full feedback. Danish Energy Welcomes the Commission's initiative to evaluate the Energy Efficiency Directive (EED) in order to align it with the EU's new and more ambitious climate targets.

Iberdrola S.A. · filed 21 Sept 2020 · source

The 2030 energy efficiency (EE) objective was set at 32.5% based on a GHG emissions reduction target of 80-95% by 2050. Consequently, in order to reach carbon neutrality by 2050, the 2030 EE objective should be increased accordingly. Iberdrola strongly supports the proposal to increase this value to 36%.

Iberdrola S.A. · filed 17 Nov 2021 · source

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Revision of the Energy Tax Directive

Iberdrola S.A. · filed 31 Mar 2020 · source

Iberdrola shares with the Commission the views that energy taxation should be a tool for climate policy and preserving the internal EU market requires harmonised energy tax framework across the MSs as one of the keystones of the Green Deal to achieve climate neutrality in the EU by 2050. Decarbonisation is a must for the whole society involving all economic sectors.

Iberdrola S.A. · filed 17 Nov 2021 · source

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Danish Energy · filed 18 Nov 2021 · source

We commend the Commission's proposal for a fundamental shift in the minimum taxation of energy. Due to the current incoherent system, which includes ambiguous definitions and national loopholes, green electricity does not receive the support it needs, despite the critical role electrification will play in Europe’s decarbonization.

CO2 emission standards for cars and vans

Iberdrola S.A. · filed 24 Nov 2020 · source

Electrification is the most effective, efficient and sustainable way to decarbonise the transport sector, achieve EU’s long-term climate objectives and reduce air pollution. The electric vehicle (EV) is the real, competitive and mature alternative to decarbonise road transport at least cost, contributing at the same time to ALL the energy and climate objectives: renewable, energy efficient (2-3 times more efficient…

Danish Energy · filed 26 Nov 2020 · source

Danish Energy highly welcomes the European Commission’s decision to revisit and strengthen the CO2 standards for cars and vans for 2030 and thanks the Commission for this opportunity to share our views on the revision. Danish Energy is a non-commercial organisation for Danish energy companies, mainly active in the electricity sector, covering activities from energy production, distribution and trading.

Iberdrola S.A. · filed 8 Nov 2021 · source

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Gas and hydrogen markets regulation

Danish Energy · filed 10 Mar 2021 · source

Danish Energy welcomes the opportunity to comment on the roadmap for the Hydrogen and Gas mar-kets Decarbonisation Package. Danish Energy is an association representing Danish electricity and gas companies. Our members include gas suppliers and companies active in the North-western Euro-pean gas markets.

Iberdrola S.A. · filed 10 Mar 2021 · source

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

Iberdrola S.A. · filed 10 Mar 2021 · source

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

Danish Energy · filed 3 Mar 2022 · source

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of EU rules on market access. Dansk Energi fully supports the initiative to provide an appropriate market framework to accommodate the increasing EU climate ambitions.

Iberdrola S.A. · filed 12 Apr 2022 · source

• CROSS-SUBSIDIES BETWEEN DIFFERENT ENERGY CARRIERS. Cross-subsidies means deviating from the cost-reflective tariffs principle, thus distorting competition between different energy vectors, which is the essence of an efficient energy system integration according to Commission's Strategy itself.

Deployment of alternative fuels infrastructure

Iberdrola S.A. · filed 4 May 2020 · source

Review of the “alternative fuel” definition Given the difficulty of reducing emissions of aviation and shipping, it is necessary to focus efforts on the decarbonisation of road transport to achieve carbon neutral economy by 2050.

Iberdrola S.A. · filed 17 Nov 2021 · source

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Danish Energy · filed 18 Nov 2021 · source

In general, we applaud the regulation's intention of facilitating the adoption, deployment, and development of charging infrastructure across Europe, as well as improving interoperability and transparency for the benefit of both customers and the green transition in transportation.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Iberdrola S.A. · filed 17 Nov 2021 · source

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Danish Energy · filed 18 Nov 2021 · source

This document comprises Danish Energy’s updated positions on: 1. ReFuelEU Aviation on ensuring a level playing field for sustainable air transport 2. FuelEU Maritime on the use of renewable and low-carbon fuels in maritime transport It is important to have ambitious European targets for decarbonization and the use of renewable energy and renewable fuels.

Gas and hydrogen markets directive (common rules)

Danish Energy · filed 3 Mar 2022 · source

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of EU rules on market access. Dansk Energi fully supports the initiative to provide an appropriate market framework to accommodate the increasing EU climate ambitions.

Iberdrola S.A. · filed 12 Apr 2022 · source

• DEPENDENCY ON FOSSIL GAS. To reduce this dependency, fossil gas-based H2 should be excluded from the definition of low-carbon H2 (even when fitted with CCS/CCU). This is especially relevant as this Directive includes measures to promote low-carbon gases, thus risking increasing such dependency. • FOSSIL FUEL COMPARATOR. The renewable and low-carbon gases injected are intended to substitute fossil gas.

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