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
Company · United States
Declared costs: €700K+ a year · in the register since 2018
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.
Twilio Inc. · filed 20 Jan 2023 · source
As a Business-to-Business (B2B) provider of cloud communication services, Twilio welcomes the laudable intent of the Cyber Resilience Act (CRA). Protecting critical telecommunications and information infrastructure is a key priority to Twilio.
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.
Twilio Inc. · filed 6 May 2026 · source
Twilio strongly supports the Commissions proposal for a European Business Wallet (EBW). As a regulated telecom operator, Twilio experience's first-hand the friction caused by fragmented, manual compliance processes across Member States, particularly regarding fraud prevention (KYC/KYBC) and regulatory reporting.
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.
Twilio Inc. · filed 2 Sept 2021 · source
Twilio -- both a user of public-sector identification schemes and a provider of authentication tools -- has followed the European Commission’s work on a European Digital Identity scheme with great interest. Twilio previously responded to the Commission’s initial consultation on this matter.
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