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Compare organizations

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.

DPA
Dutch Payments Association

Industry association · Netherlands

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

Consumer organization · Portugal

15
files engaged
of 583 tracked
15
positions filed
in those 583 files
7.5
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2016

Files both filed on (2)

Payment services in the internal market · Payment services and electronic money services in the Internal Market

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.

Payment services in the internal market

DECO · filed 16 Aug 2023 · source

DECO welcome this proposal. We consider the PSD2 needs to be profoundly revised especially regarding fraud, liability and redress. General comments: The proposals to address consumer/user confidence by enhancing their protection are very much welcome.

Dutch Payments Association · filed 3 Oct 2023 · 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.

Payment services and electronic money services in the Internal Market

DECO · filed 16 Aug 2023 · source

DECO welcome this proposal. It is essential to have a thorough review of the PSD2. We agree with the conclusion of the impact assessment regarding consumers' at risk of fraud. COMMENTS Scope (Articles 1 and 2 and Recitals 13 and 68) The proposal for a Directive on licensing and supervision of payment institutions is largely based on Title II of PSD2, regarding Payment Service Providers, which only applies to payment…

Dutch Payments Association · filed 3 Oct 2023 · 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 (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.

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