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.
EMISA welcomes and supports the objective of the DMA for fair and contestable digital markets. Most important is that the scope of the proposal becomes as broad as this objective and focuses on gatekeepers that can foreclose and distort competition from their direct competitors on the platform.
Please find Bitkom's five principles for the functioning of the digital economy and fair competition attached: 1.) Retain core competition mechanics: Scope should be based on objective evidence. 2.) Taking diversity into account: Obligations should not follow a one size fits all approach. 3.) Reliable rules: Application and rules must be clear and targeted.
In order to help build a circular economy and more sustainable consumption, EMISA wishes to highlight the importance of industrial sectors and the effects of the ongoing process of digitalisation in the context of repair and reuse of goods.
Bitkom e.V. is the German Digital Association and represents more than 2000 member companies from the digital economy. Bitkom members employ more than 2 million employees in Germany. Members include more than 1000 medium-sized businesses, more than 500 start-ups and almost all global players. Thank you for the opportunity to comment and our detailed feedback can be found in the attached file.
Filed in German · English published by the European Commission
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