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Compare organizations

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.

EDF
4
files engaged
of 583 tracked
4
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
DEC
DECO

Consumer organization · Portugal

15
files engaged
of 583 tracked
15
positions filed
in those 583 files
7.5
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2016

Files both filed on (4)

Framework for Financial Data Access · Instant payments in euro · Payment services in the internal market · Payment services and electronic money services in the Internal Market

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.

Framework for Financial Data Access

DECO · filed 16 Aug 2023 · source

DECO welcome this proposal. General comments: Acknowledging the objective of promotion of a data driven economy, it is important that there is a regulatory framework to establish the rules by which data sharing happens. This is particularly relevant for financial data as it entails sensitive information of natural persons and firms.

European Digital Finance Association · filed 1 Nov 2023 · source

European Digital Finance Association (EDFA) welcomes the opportunity to share its position on the EU payment services legislative package presented by the European Commission on 28th June 2023. EDFA hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector.

Instant payments in euro

DECO · filed 21 Dec 2022 · source

DECO, the Portuguese Consumer Protection Association, welcomes the proposal for a Regulation on Instant payments (IPs). To achieve a widespread take up of IPs, especially from consumers, it is crucial to have a regulatory framework making them available, accessible, and secure.

European Digital Finance Association · filed 5 Jan 2023 · source

European Digital Finance Association and its members representing thousands of fintechs throughout Europe welcome the proposed regulation to cater for speed in payment transfers in the consumer perspective. We acknowledge the fact that the financial system is not able to provide instant payments to European citizens at large.

Payment services in the internal market

DECO · filed 16 Aug 2023 · source

DECO welcome this proposal. We consider the PSD2 needs to be profoundly revised especially regarding fraud, liability and redress. General comments: The proposals to address consumer/user confidence by enhancing their protection are very much welcome.

European Digital Finance Association · filed 1 Nov 2023 · source

European Digital Finance Association (EDFA) welcomes the opportunity to share its position on the EU payment services legislative package presented by the European Commission on 28th June 2023. EDFA hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector.

Payment services and electronic money services in the Internal Market

DECO · filed 16 Aug 2023 · source

DECO welcome this proposal. It is essential to have a thorough review of the PSD2. We agree with the conclusion of the impact assessment regarding consumers' at risk of fraud. COMMENTS Scope (Articles 1 and 2 and Recitals 13 and 68) The proposal for a Directive on licensing and supervision of payment institutions is largely based on Title II of PSD2, regarding Payment Service Providers, which only applies to payment…

European Digital Finance Association · filed 1 Nov 2023 · source

European Digital Finance Association (EDFA) welcomes the opportunity to share its position on the EU payment services legislative package presented by the European Commission on 28th June 2023. EDFA hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector.

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