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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.

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
BV
Bitkom e.V.

Industry association · Germany

53
files engaged
of 583 tracked
61
positions filed
in those 583 files
7
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €1M+ a year · in the register since 2008

Files both filed on (2)

European Digital Identity framework · Instant payments in euro

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

European Payment Institutions Federation (EPIF) · filed 3 Sept 2020 · source

EPIF welcomes the opportunity to comment on the Commission’s Inception Impact Assessment on the Revision of the eIDAS Regulation aimed at improving its effectiveness, extend its application to the private sector and promote trusted digital identities for all Europeans.

Bitkom e.V. · filed 2 Sept 2021 · source

Bitkom welcomes the Commission’s draft, as it is another important building block for secure digital identities and trust services in the European Union. Europe’s digital sovereignty will be strengthened by establishing digital identities and allowing them to be used independently by EU citizens across the EU. Bitkom thanked for the opportunity to comment in the consultation process. Please find attached the opinion.

Filed in German · English published by the European Commission

Instant payments in euro

European Payment Institutions Federation (EPIF) · filed 7 Apr 2021 · source

EPIF welcomes the opportunity to provide our views to the Commission Inception Impact Assessment on Instant Payments. We would like to take this opportunity to share with you some general comments that our members have on this issue.

Bitkom e.V. · filed 7 Apr 2021 · source

According to Bitkom, instant payments offer added value across all payment use cases. As supporters of a technology-neutral approach, however, we also want to stress the merit of digital payment solutions in general. Hence, we consider instant payments as complementary to existing products and as enabler for new payment solutions and products (e.g. Instant Lending).

Bitkom e.V. · filed 3 Jan 2023 · source

Bitkom welcomes the Commissions proposal to accelerate the rollout of instant payments as an opportunity to drive further innovation in payment services. We recognise the opportunity to provide feedback on the proposed regulation. Our preliminary position paper lays out our ideas on how the draft regulation can be further developed with regard to the scope, pricing, and IBAN name checking.

Filed in German · English published by the European Commission

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