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.
NGO · Germany
Industry association · Germany
Declared costs: €2.8M+ a year · in the register since 2008
A European Health Data Space · Harmonising certain aspects of insolvency law
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.
German Insurance Association (GDV) · filed 3 Feb 2021 · source
The German Insurance Association (GDV) welcomes the European Commission’s plans for a European Health Data Space (EHDS). Effective and secure use and re-use of health-related data has the potential to create immense benefits for the well-being of patients and society. The roadmap shows that a plethora of issues and barriers currently persist which prevent us from fully exploiting that potential.
Deutsche Sozialversicherung · filed 28 Jul 2022 · source
The German Social Insurance Agency welcomes the objective of creating a common health data space (EHDS). It offers an opportunity for an added value for patients and healthcare systems, both through digital, cross-border access to health data for medical treatment and its meaningful integration for research.
Filed in German · English published by the European Commission
German Insurance Association (GDV) · filed 28 Jul 2022 · source
The proposal for a Regulation on the European Health Data Space (EHDS) is a welcome attempt to strengthen patients’ rights in relation to their elec-tronic health data and to foster sharing and use of electronic health data for the public benefit. However, vague definitions and the resulting inadvertent-ly extensive scope of several provisions are likely to impede the uptake of the EHDS.
German Insurance Association (GDV) · filed 8 Dec 2020 · source
The German Insurance Association (GDV) welcomes the initiative “Enhancing the convergence of insolvency laws” and supports the recommendation to address the fragmentation of insolvency laws in EU-Member States. Insurance companies are amongst the largest institutional investors in Europe.
German Insurance Association (GDV) · filed 15 Mar 2023 · source
The German insurers welcome the proposed directive insofar as it aims to strengthen the creditors position in insolvency proceedings across the European Union and to increase their chances to influence the proceedings, in particular through creditors committees.
Deutsche Sozialversicherung · filed 17 Mar 2023 · source
On 7th The European Commission published its proposal for a Directive on the harmonisation of certain aspects of insolvency law on December 2022. The aim of the draft Directive is to reduce the existing fragmentation within national insolvency laws. To that end, it is intended, inter alia, to harmonise the conditions for bringing an action for annulment.
Filed in German · English published by the European Commission
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