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 · Netherlands
Declared costs: €200K+ a year · in the register since 2010
Industry association · Belgium
Declared costs: €900K+ a year · in the register since 2008
Rationalisation of reporting requirements · Framework for Financial Data Access · New EU system for the avoidance of double taxation in the field of withholding taxes · Review of the VAT rules for financial and insurance services
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.
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.
PensionsEurope · filed 29 Nov 2023 · source
PensionsEurope welcomes this EC call for evidence initiative that aims to identify reporting requirements in EU legislation that can be removed or rationalized without undermining the policy objectives of the EU. Pension funds are important due to their social role.
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.
PensionsEurope · filed 31 Oct 2023 · source
PensionsEurope welcomes the the Commission's proposal for a framework for Financial Data access (FIDA) which is a key component of the Commission's digital finance strategy presented in September 2020. We also would like to highlight that experiences from other financial services such as payment services cannot be simply applied to the Institutions for occupational retirement provision (IORPs) which are included in…
PensionsEurope · filed 25 Oct 2021 · source
We welcomes the EC’s roadmap on the new EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes (WHT). We support the current EC´s mandate call for removing all barriers to the completion of the CMU – particularly in the field of simplifying taxation.
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.
PensionsEurope · filed 18 Sept 2023 · source
PensionsEurope welcomes the European Commission's proposal for a Faster and Safer Relief of Excess Withholding Taxes (FASTER). As cross-border investors, with 2.4 trillion euros of assets for EEA institutions for occupational retirement provision (IORPs) at the end of 2022, pension funds bear witness to investment barriers and costs within the single market which ultimately impact negatively pension fund members and…
Dutch Federation of Pension Funds · filed 19 Nov 2020 · source
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).
PensionsEurope · filed 19 Nov 2020 · source
Read attached PensionsEurope's complete feedback. In summary: PensionsEurope supports the EC’s objective to simplify the life of taxpayers operating in the Single Market and we welcome the review of the VAT rules.
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