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.
The European Women’s Lobby (EWL) welcomes the European Commission’s (EC) initiative on preventing and combatting gender-based violence and domestic violence. By integrating in EU law the standards of the Istanbul Convention, this initiative is of the utmost importance as resulting legislation could save countless lives and prevent significant trauma and violence in the lives of women and girls across Europe.
The European Women’s Lobby (EWL) recognises that this Directive proposal is a historic landmark and that it fills significant legislative gaps on violence against women and girls (VAWG) across the EU, especially on the legal definition of rape, the recognition of female genital mutilation as a criminal offence and the prosecution of key forms of online violence.
The focus of the directive is to criminalise GBV. While this gives a strong signal that GBV is unacceptable in the European Union, it is an insufficient tool to combat violence and to protect victims, as the title of the draft directive promises. Criminalisation is not a solution that actually works, and it is not cost-efficient (see attachment). What does work and what is cost-efficient is prevention, i.e.
EWL believes that the current EU framework on victims’ rights does not fully grant their rights to victims of male violence against women and girls (VAWG). EWL calls for a comprehensive EU framework to ensure equal levels of protection and access to justice for all victims of VAWG, including child victims, all centered in a Directive.
Tackling and preventing violence against women and their children must be a key strategic priority now and in the future, if the EU aims to improve the situation of crime victims, particularly in view of the ongoing COVID-19 pandemic.
Garance asbl welcomes the initiatives of the European Commission to address harmful practices against women and girls. Firstly, harmful practices are a form of gender-based violence, and gender-based violence is a harmful practices. Therefore, the two current initiatives on these issues should be developed together or even merged in order to avoid any gaps in the provision of rights and services in the EU.
The European Women’s Lobby (EWL) suggests that harmful practices against women and girls should be understood in a broader way and include all kinds of violence against women and girls, whether it is because of the new forms of violence that emerged through the era of digitalisation and that was not necessarily foreseen in the Istanbul Convention - e.g.
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