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.
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.
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.
Insurance Europe welcomes the European Commissions initiative to identify reporting requirements in EU legislation that can be removed or rationalised without undermining policy objectives. The insurance industry applauds the EC for its commitment to rationalise and simplify reporting requirements for companies and administrations and for its objective of reducing such burdens by 25%, in line with the strategy to…
Open finance, if designed with the right framework, has the potential to positively impact both consumers and insurers. However, it is important to get the framework right, so that the potential can truly be achieved. This raises important considerations in relation to consent management, the scope of the data sharing and ensuring a level playing field among market participants.
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.
Insurance Europe welcomes the possibility to comment on this roadmap. Provisions around withholding tax procedures for cross-border portfolio investors or shareholders in the EU, which are different between member states, often pose a challenge to insurers in regard to cross-border investment, due to their complexity and the related costs.
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.
Dutch pension funds are strongly committed to deliver pension services on behalf of and in the interest of those who work in the Netherlands, either living in the Netherlands or any other Member State. They seek for the lowest cost and the appropriate investment policy (maximizing risk-adjusted returns) and structure their activities according to these objectives (either through insourcing or outsourcing).
Insurance Europe welcomes the possibility to comment on the Roadmap/Inception Impact Assessment for the review of the VAT rules for financial and insurance services. We believe that an effort is required to harmonise VAT rules across Europe, establish a level playing field on VAT for all financial services providers, create legal certainty and ensure that European VAT law is fit and proper for the modern business…
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