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 Payments Association (DPA) organises collective and non-competitive tasks in the national payment system for its members. The DPA and its members welcome the European Commissions proposal for a Regulation on payment services in the internal market (PSR). We have witnessed the Commissions thorough review process of PSD2 and are pleased to see that the Commission has proposed to make targeted amendments.
We welcome the choice of a Regulation for the provisions on the scope of payment services (PSs), transparency and rights and obligations as it goes in the direction to create a uniform EU regulatory framework avoid fragmentation and competitive disparities. We agree that the proposals entail an evolution of the payment sector leveraging the investment already made (e.g.PSD2 dedicated interfaces).
The Dutch Payments Association (DPA) organises collective and non-competitive tasks in the national payment system for its members. The DPA and its members welcome the European Commissions (Commission) proposal for a new Directive on payment services and electronic money services in the Internal Market (PSD3). We are pleased to see that the Commission made targeted amendments to PSD2.
We welcome the choice of a Regulation for the provisions on the scope of payment services (PSs), transparency and rights and obligations as it goes in the direction to create a uniform EU regulatory framework avoid fragmentation and competitive disparities. We agree that the proposals entail an evolution of the payment sector leveraging the investment already made (e.g.PSD2 dedicated interfaces).
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