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.
Industry association · Germany
Declared costs: €100K+ a year · in the register since 2010
Industry association · Belgium
Declared costs: €3.5M+ a year · in the register since 2011
VAT in the Digital Age · Digital Finance: amending Directive regarding Digital Operational Resilience requirements
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.
DGRV - Deutscher Genossenschafts- und Raiffeisenverband e.V. · filed 3 Apr 2023 · source
Dear EU Commission, We thank you for the opportunity to comment on the proposal "VAT in the digital Age" (ViDa). The DGRV - German Cooperative and Raiffeisen Confederation represents both the umbrella organization and auditing association of the German cooperative sector with 19.5 million members in about 5.200 mostly small and medium sized cooperative entities.
DIGITALEUROPE · filed 4 Apr 2023 · source
We welcome the opportunity to provide our feedback on the VAT in the Digital Age proposal of the European Commission. We fully support the European Commissions ambition to improve the VAT system through the use of digital tools, reducing VAT-related barriers for cross-border trade in the EU and making the VAT system better for businesses, while also more resilient to fraud.
DGRV - Deutscher Genossenschafts- und Raiffeisenverband e.V. · filed 22 Oct 2020 · source
Thank you for the opportunity to comment on the European Commission’s Digital Finance Package. The DGRV — Deutscher Genossenschaftsund Raiffeisenverband e.V. currently brings together 5.330 cooperatives with 19,8 million members.
Filed in German · English published by the European Commission
DGRV - Deutscher Genossenschafts- und Raiffeisenverband e.V. · filed 22 Oct 2020 · source
Thank you for the opportunity to comment on the European Commission’s Digital Finance Package. The DGRV — Deutscher Genossenschaftsund Raiffeisenverband e.V. currently brings together 5.330 cooperatives with 19,8 million members.
Filed in German · English published by the European Commission
DIGITALEUROPE · filed 15 Feb 2021 · source
The draft DORA regulation is an opportunity to further accelerate the digital transformation of finance and show the EU’s global leadership in defining a first-of-its-kind framework for outsourced ICT operations in financial services. Yet, unclear and potentially overlapping provisions in the existing draft risk to dramatically hamper the achievement of these goals.
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