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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.

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
0.5
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2016

BV
Bitkom e.V.

Industry association · Germany

53
files engaged
of 583 tracked
61
positions filed
in those 583 files
7
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €1M+ a year · in the register since 2008

Files both filed on (2)

A European Health Data Space · European data governance (Data Governance Act)

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.

A European Health Data Space

Bitkom e.V. · filed 3 Feb 2021 · source

Bitkom strongly welcomes the European Commission’s efforts to create a European Health Data Space (EHDS) to unlock the potential of health data for sustainable and resilient healthcare systems. Access and (re)use of health data are preconditions to a digital transformation of healthcare systems and set the cornerstones for patient-oriented and data-driven health ecosystems for the future.

ECHAlliance - European Connected Health Alliance · filed 4 Feb 2021 · source

The ECHAlliance is a global network of Digital Health Alliances that connects 78 countries in Europe, USA, Canada, China, Africa, Asia, the Caribbean and Americas and the Pacific, including stakeholders from government, health & social care providers, companies and start-ups, researchers, insurances, patient groups and citizens.

Bitkom e.V. · filed 27 Jul 2022 · source

Bitkom welcomes the opportunity to give feedback on the Commission’s proposal. We are convinced that a uniform European health Data Space with transparent, efficient and innovation-promoting conditions is the central component of a connected and learn-as-you-go health sector. Our position paper provides an initial assessment of the proposal and highlights a number of points, which should be critically reviewed.

European data governance (Data Governance Act)

ECHAlliance - European Connected Health Alliance · filed 4 Feb 2021 · source

The ECHAlliance is a global network of Digital Health Alliances that connects 78 countries in Europe, USA, Canada, China, Africa, Asia, the Caribbean and Americas and the Pacific, including stakeholders from government, health & social care providers, companies and start-ups, researchers, insurances, patient groups and citizens.

Bitkom e.V. · filed 8 Feb 2021 · source

If done right, the European Commission’s initial proposal on the Data Governance Act (DGA) has the potential to be an important step towards a European data economy. While previous discussions about the use of data have focused primarily on the important topic of data protection, there is an increasing awareness for the innovative potential of data, which is why we welcome that the DGA addresses all types of data…

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