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.
ECRE does not support the measures proposed, which will have an adverse effect on the right to asylum without adequately responding to the situation at the EU’s borders with Belarus. The main fundamental rights affected by the proposal are the right to human dignity (Article 1 EU Charter of Fundamental Rights (CFREU)), the right to asylum (Article 18 CFREU), the prohibition of torture and inhuman or degrading…
PICUM is extremely concerned by the impact on the rule of law in the EU as well as on migrants’ fundamental rights of the Commission’s proposal for a Council Decision establishing provisional measures for the benefit of Latvia, Lithuania and Poland. We are alarmed by the procedure through which this file has been proposed, as well as the contents of the proposal.
Like Dublin IV before it, the overall approach of the Regulation on asylum and migration management (RAMM) to responsibility allocation is to maintain the status quo but add “corrective” solidarity mechanisms intended to compensate for the outcomes of the standard rules and make them fairer. A deeper overhaul of the criteria on sharing of responsibility is vital to address the system’s dysfunctionalities.
The Return Sponsorship scheme The proposed “return sponsorship” scheme raises more questions than answers. Firstly, the unclear division of responsibilities between the “sponsoring” state and the “benefitting” state risks creating legal gaps in accountability as well as serious breaches of fundamental rights.
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