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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.

DFV
DIE FAMILIENUNTERNEHMER e.V.

Industry association · Germany

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
1
declared FTE
self-declared
1
EP accreditations
as declared to the register

Declared costs: €100K+ a year · in the register since 2015

EFB
European Family Businesses

Industry association · Belgium

5
files engaged
of 583 tracked
6
positions filed
in those 583 files
2.8
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €300K+ a year · in the register since 2010

Files both filed on (2)

Rationalisation of reporting requirements · Debt equity bias reduction allowance (DEBRA)

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.

Rationalisation of reporting requirements

DIE FAMILIENUNTERNEHMER e.V. · filed 30 Nov 2023 · source

Family entrepreneurs expressly welcome the Commission’s approach to reducing red tape in the field of documentary requirements. In view of the new obligations created in the current parliamentary term and the reporting obligations that have already been initiated and are being implemented, the requirement for a 25 % reduction is undoubtedly too small.

Filed in German · English published by the European Commission

European Family Businesses · filed 1 Dec 2023 · source

When we take the example of sustainability reporting, businesses have to dedicate more time and resources to comply with the Corporate Sustainability Reporting Directive (CSRD) requirements. The sustainability reporting of the CSRD requires external auditing which in turn, It is paramount that legislation is made easily applicable not only for the benefit of businesses which should not have to duplicate their…

Debt equity bias reduction allowance (DEBRA)

DIE FAMILIENUNTERNEHMER e.V. · filed 22 Jul 2022 · source

DIE FAMILIENUNTERNEHMER have for decades advocated an interest adjustment of the profit tax base with an indexed, increasing flat interest rate for the reasons mentioned above. In this respect, the initiative of the EU Commission presented in 2021 under the title DEBRA met with approval in principle from DIE FAMILIENUNTERNEHMER.

European Family Businesses · filed 26 Jul 2022 · source

Below are some suggestions for possible improvements or clarifications that we believe should be included in the proposal for a Directive (“DEBRA”). ONE.- It is not clear from the wording of the proposal for a directive how the reduction will be calculated in the case of entities belonging to a tax group.

Filed in Spanish · English published by the European Commission

European Family Businesses · filed 26 Jul 2022 · source

European Family Businesses (EFB) welcomes the effort and work of the European Commission in its attempts to tackle the Debt and Equity Bias. EFB would like to propose the following: 1. In relation to the provisions that would restrict the deductibility of interest from debt, whilst we recognise the reasoning behind the inclusion of such provisions, EFB would caution against this approach.

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