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 « context » paragraph shows how clear rules for access and use of the data are essential for the success of the Single Market for data but also how important it is to consider the features of the different sectors. GFII works for years on data produced and re-used by public and private professionals, whose end-users are also professionals.
Insurance Europe welcomes the overall objectives set out in the roadmap, namely: - to make more data held by the public sector usable for research and innovative uses (ie development of new products and services); - to allow individuals to consent to greater access to their data for the common good; and - to enhance overall data use in the economy by lowering transaction costs, addressing interoperability and…
General comments Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good.
GFII has provided written contributions and participated to the focus group discussions and validation workshop on “the impact assessment study on the list of HVDS to be made available by Member States under the PSI directive”, recently organised and carried out by Deloitte for the DG Connect. These contributions have been mainly dedicated to the “company & company ownership” HVDS category.
Insurance Europe welcomes the objective of this initiative to ensure that a common EU-wide layer of public sector datasets is easily and freely available for re-use, which can lead to significant benefits for society, the environment and the economy. Public institutions can provide invaluable sources of data due to their comprehensiveness and the quality of the datasets.
Insurance Europe welcomes the possibility to comment on the European Commission draft Implementing Regulation laying down a list of specific high-value datasets and the arrangements for their publication and re-use.
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