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 · Italy
Declared costs: €50K+ a year · in the register since 2019
Industry association · Germany
Declared costs: €1M+ a year · in the register since 2008
Cyber Resilience Act · Establishment of European Business Wallets · European Digital Identity framework
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.
INFOCERT SPA · filed 20 Jan 2023 · source
As a Qualified Trust Service Provider, InfoCert firmly believes that actions such as the proposed initiative can positively assist the development on the topic of cyber security on a European level. In the attached feedback file InfoCert proposes several focus points for a fruitful development of the topic.
Bitkom e.V. · filed 20 Jan 2023 · source
Bitkom appreciates the opportunity to provide feedback on the Commissions proposal for a Cyber Resilience Act. Please find our position paper attached. We welcome the proposal to create a more efficient legal framework to improve cybersecurity in Europe. Nevertheless, some important aspects should be optimized and clarified during the legislative process.
Bitkom e.V. · filed 11 Jun 2025 · source
In the attached position paper, Bitkom highlights the key challenges organizations face in B2B and B2G contexts and to some extent in B2C, B2M and B2E and outlines essential use cases alongside technical and legal requirements to be integrated into the forthcoming EU legislation on the EUBW.
INFOCERT SPA · filed 12 Jun 2025 · source
InfoCert is a leader Qualified Trust Service Provider (Certification Authority) in Europe and in digitalization solutions, enabling the digital transformation of every high-value business process. Operating in over 60 countries, it is the trusted partner of over 5,600 major companies in Banking & Financial Services, Pharma, Telco & Utilities, HealthCare, and Insurance sectors.
Bitkom e.V. · filed 6 May 2026 · source
Bitkom supports the European Business Wallet in principle as an important element of a European trust infrastructure for digital business and administrative processes. However, against the backdrop of the current negotiations on the proposed regulation and the recently discussed amendments, Bitkom sees a need for targeted improvements: Clear and swiftly adopted implementing acts are required, along with ambitious…
INFOCERT SPA · filed 2 Sept 2021 · source
The attached document reflects the InfoCert Group contribution to the “have your say” consultation on the EC Proposal for a Regulation of the European Parliament and of the Council, amending Regulation (EU) No 910/2014 as regards establishing a framework for a European Digital Identity.
Bitkom e.V. · filed 2 Sept 2021 · source
Bitkom welcomes the Commission’s draft, as it is another important building block for secure digital identities and trust services in the European Union. Europe’s digital sovereignty will be strengthened by establishing digital identities and allowing them to be used independently by EU citizens across the EU. Bitkom thanked for the opportunity to comment in the consultation process. Please find attached the opinion.
Filed in German · English published by the European Commission
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