Side by side
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.
Company · Hungary
Declared costs: €100K+ a year · in the register since 2022
Company · Spain
Declared costs: €200K+ a year · in the register since 2013
Gas and hydrogen markets directive (common rules) · Evaluation of ACER and of the ACER Regulation
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
FGSZ Ltd. · filed 12 Apr 2022 · source
FGSZ Ltd. is committed to take part in building the future hydrogen grid, but due to the peculiar situation of the nascent hydrogen market – neither demand, supply, nor mature technology and extensive infrastructure exist yet – we believe that certain provisions in the Hydrogen and Gas Market Decarbonisation Package proposal are holding back the quick transition to a decarbonised gas market.
Enagás · filed 12 Apr 2022 · source
Enagás welcomes the Commision's legislative proposal. Please find below comments (amendments in pdf attached): 1. Vertical unbundling: the ownership unbundling model should be favoured … since it is the most effective one and entailing less regulatory monitoring efforts. Enagás supports the proposal for HNOs and encourages to foresee a transition for gas TSOs to OU by 31 Dec 2030.
FGSZ Ltd. · filed 6 May 2026 · source
FGSZ welcomes the European Commissions consultation on the efficiency and effectiveness of ACER in delivering its mandate. ACER plays a central role in advancing integrated European electricity and gas markets and in maximising the economic value they generate for the European Union.
Enagás · filed 6 May 2026 · source
Enagás, the Transmission System Operator for natural gas and provisional hydrogen transmission network operator in Spain, welcomes the opportunity to share its thoughts on ACER evaluation. ACER Framework Guidelines & Network Codes: more flexibility required. ACERs Recommendations: Legal consistency with binding EU legislation. ACERs role under REMIT framework: interpretative clarity under the REMIT framework.
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