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.
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.
The Electronic Money Association (EMA), established in 2001, is the trade body for European and UK E-Money Institutions (EMIs), Payment Institutions (PIs), Crypto Assets Providers (CASPs), and Credit Institutions (CIs) providing innovative payments solutions.
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.
The EMA welcomes the Commissions proposals to improve the supply of instant payments across Europe, and tackle the key issues that have hampered the uptake of instant payment in euro. We share the Commissions view that SEPA instant payments have the capacity to form the foundations to support the EU retail payments strategy.
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.
The Electronic Money Association (EMA), established in 2001, is the trade body for European and UK Crypto Assets Providers (CASPs), Payment Institutions (PIs), E-Money Institutions (EMIs), and Credit Institutions (CIs) providing innovative payments.
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.
The Electronic Money Association (EMA), established in 2001, is the trade body for European and UK Crypto Assets Providers (CASPs), Payment Institutions (PIs), E-Money Institutions (EMIs), and Credit Institutions (CIs) providing innovative payments.
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