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.
GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Regulation and contribute to the legislative debate. Please find attached our detailed comments and positions on the proposal. The German Banking Industry Committee (GBIC) is the joint committee operated by the central associations of the German banking industry.
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.
GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Directive and contribute to the legislative debate. Please find attached our detailed comments and positions on the proposal. The German Banking Industry Committee (GBIC) is the joint committee operated by the central associations of the German banking industry.
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