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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
GBI
German Banking Industry Committee

Industry association · Germany

37
files engaged
of 583 tracked
45
positions filed
in those 583 files
13
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: under €10K a year · in the register since 2009

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.

German Banking Industry Committee · filed 2 Sept 2021 · source

DEAR Ladies and Gentlemen, please find the German Banking Industry Committee’s comments on the EU Digital ID Scheme. The comments are written in German, but a convenience translation into English is included. Child regards, [name removed] (DSGV)

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.

German Banking Industry Committee · filed 7 Apr 2021 · source

We would like to express our concern that the first part of the consultation on Instant Payments (targeted consultation) was published before the end of the deadline for feedback on the Impact Assessment. The SEPA Instant credit transfer ("Instant Payments/ SCT Inst") is an important enrichment of the payments service offering in SEPA, which is well accepted by customers from an actual demand.

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