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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.

EGB
Erste Group Bank AG

Company · Austria

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
2.2
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €300K+ a year · in the register since 2014

FD
Finance Denmark

Industry association · Denmark

29
files engaged
of 583 tracked
34
positions filed
in those 583 files
10
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €1.8M+ a year · in the register since 2012

Files both filed on (2)

European Digital Identity framework · Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

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.

European Digital Identity framework

Finance Denmark · filed 28 Aug 2020 · 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.

Erste Group Bank AG · filed 3 Sept 2020 · source

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.

Finance Denmark · filed 1 Sept 2021 · source

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.

Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

Finance Denmark · filed 9 Sept 2020 · source

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.

Erste Group Bank AG · filed 11 Sept 2020 · source

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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