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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.

DFP
Dutch Federation of Pension Funds

Industry association · Netherlands

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

Declared costs: €200K+ a year · in the register since 2010

EBF
European Banking Federation

Trade union · Belgium

48
files engaged
of 583 tracked
56
positions filed
in those 583 files
12.9
declared FTE
self-declared
12
EP accreditations
as declared to the register

Declared costs: €4M+ a year · in the register since 2008

Files both filed on (3)

Rationalisation of reporting requirements · Framework for Financial Data Access · New EU system for the avoidance of double taxation in the field of withholding taxes

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

Dutch Federation of Pension Funds · filed 28 Nov 2023 · source

The Dutch Federation of Pension Funds welcomes the European Commissions initiative to rationalize reporting requirements. We support the alignment of reporting requirements and underline the importance of data quality.

European Banking Federation · filed 1 Dec 2023 · source

The European Banking Federation (EBF) welcomes the opportunity to put forward our comments on the European Commissions call for evidence on its initiative for the rationalisation of reporting requirements. The EBF is very supportive of all efforts for rationalizing and simplifying reporting requirements not only to improve the system but also helping to increase the competitiveness of EU businesses.

Framework for Financial Data Access

European Banking Federation · filed 2 Aug 2022 · source

The European Banking Federation (EBF) welcomes the opportunity to comment on the European Commission’s Call for Evidence on an “Open Finance Framework – enabling data sharing and third-party access in the financial sector.” A European data economy which unlocks new opportunities for customers – individuals and firms – through increased data sharing is a priority that the European banking sector welcomes in the…

Dutch Federation of Pension Funds · filed 11 Oct 2023 · source

The Dutch Federation of Pension Funds welcomes the European Commissions proposal for the Financial Data Access Regulation. Pension data are an important part of an individuals financial situation. Providing access to occupational and personal pension data assists pension fund members and beneficiaries in obtaining a more comprehensive overview of pension entitlements and personal finances.

New EU system for the avoidance of double taxation in the field of withholding taxes

Dutch Federation of Pension Funds · filed 15 Sept 2023 · source

The Dutch Federation of Pension Funds would like to give its support to the legislative proposal FASTER for faster and safer relief of excess withholding taxes. We highlight the benefits of the proposed directive for a uniform and quick withholding tax relief system. We call on EU policy makers to make quick progress on FASTER, so it enters into application as soon as possible.

European Banking Federation · filed 18 Sept 2023 · source

The EBF welcomes efforts at simplification and digitisation of withholding tax processes within the Union. Slow and complex withholding tax reclaim processes remain barriers to efficient investment. A simple, swift, and safe system would encourage intra-union and foreign investment. Nevertheless, the proposed rules remain complex and would require significant due diligence and reporting.

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