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…
The Red Cross EU Office (RCEU) represents the 27 National Red Cross Societies in the European Union, the Norwegian Red Cross, the Icelandic Red Cross and the International Federation of Red Cross and Red Crescent Societies (IFRC). We hereby wish to share our serious humanitarian concerns on the impact of this proposal on the dignity and rights of migrants in the countries concerned.
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.
In terms of criteria and mechanisms for determining the Member State responsible, the Red Cross EU Office observers that despite the shortcomings of the Dublin system, the Pact does not propose removing the obligation for asylum seekers to remain in the country where their application was first registered.
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