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 · United Kingdom
Declared costs: €1M+ a year · in the register since 2014
Company · Germany
Declared costs: €1M+ a year · in the register since 2009
Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic) · Exemption of certain third country spot foreign exchange benchmarks and the designation of replacements for certain benchmarks in cessation
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.
HSBC Holdings PLC · filed 11 Sept 2020 · source
HSBC Global Banking & Markets (HSBC GBM) welcome the Commission’s initiative to improve market conditions to allow capital markets to manage the challenges and support the recovery from the COVID-19 pandemic. HSBC GBM welcomes the Commission’s stated goals to increase the availability of information on SME and fixed income instruments to facilitate investment in the real economy and free up resources for both firms…
Deutsche Börse Group · filed 11 Sept 2020 · source
Deutsche Börse Group (DBG) welcomes the proposed Delegated Act on SME Research. We share the Commission’s view that exempting small and mid-cap enterprises (SMEs) from the unbundling rule will contribute to an increase of research coverage for those. Moreover, we agree with the definition of SMEs (market capitalisation of < EUR 1 bn over 12 months period).
Deutsche Börse Group · filed 15 Apr 2020 · source
1. Critical benchmarks: Deutsche Börse Group (DBG) does not consider that competent authorities should have broader powers regarding methodology modifications for critical benchmarks. On the contrary, we consider that this could create uncertainty for users regarding the continued provision of such benchmarks.
HSBC Holdings PLC · filed 6 Oct 2020 · source
HSBC welcomes the opportunity to respond to the European Commission’s review of the Benchmarks Regulation. In this submission we focus our comments on the proposed new Article 23A (powers relating to IBOR transition). We support the Commission’s proposal for a legislative solution for the transition of legacy LIBOR contracts.
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