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.
Finance Denmark welcomes the initiative to revise the 2014 eIDAS Regulation, extending it to the private sector and promoting trusted identities, in general, across Europe. In Denmark, we have had a well-functioning public/private digital ID solution since 2010 called NemID. It is a public private partnership collaboration between the Danish banks and the public sector.
In general, the Commission’s assessment of the current situation seems adequate, especially since interoperability and extensions to digital validation are crucial for a sovereign digital market in Europe. Because of the different pace of digitalization across the EU, several Member States have already implementing digital validation on top of identification.
Extract of the full document in Annex: We welcome the intention to develop an EU digital ID scheme with an ambition to ensure a much greater use of digital authentication across the member states. Particularly, we note that this is supported by broadening the scope of the eIDAS regulation to also cover services offered by private companies.
Finance Denmark acknowledge that it is evident that there has been a decline in research coverage for small and mid-cap companies, but we do not believe that rolling back the unbundling regime is not the right way to solve this chal-lenge. We see issuer sponsored research as a much better tool to solve this chal-lenge.
We welcome the European Commission's consultation and strongly support the proposed exemption of research on SMEs with a market capitalization of up to EUR 1 bn. As one of the largest banking groups in CEE, we have been observing a significant drop in the availability of SME research since the application of the current cost unbundling regime.
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