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.
Industry association · Ireland
Declared costs: €400K+ a year · in the register since 2017
Industry association · Belgium
Declared costs: €6M+ a year · in the register since 2010
Retail investor protection rules · Framework for Financial Data Access · Retail Investment Strategy
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.
AFME · filed 31 May 2022 · source
1. AFME responded to the European Commission’s EU Strategy for Retail Investors consultation on 3rd August 2021. Inducements and quality of advice AFME members are not supportive of establishing an outright ban on inducements.
Insurance Ireland · filed 28 Aug 2023 · source
Ireland is a global hub for (re)insurers, captives and insurtechs. Irish insurers service customers across the EU, making Ireland the fourth largest insurance market in the EU and no.1 exporter of life and non-life insurance. Irelands life insurers have an outstanding expertise in providing high-quality services to their customers and allowing them to participate in capital markets.
AFME · filed 28 Aug 2023 · source
In the set of recommendations attached to this submission, AFME outlines our detailed views on the European Commissions Retail Investment Strategy proposals for the Omnibus Directive amending, among others, the Markets in Financial Instrument Directive (MiFID) and the Regulation amending the Regulation on key information documents for packaged retail and insurance-based investment products (PRIIPs).
Insurance Ireland · filed 31 Oct 2023 · source
Insurance Ireland welcomes the FiDA proposal. However, we outline some considerations: Scope.We suggest a phased approach by line of business with pre-defined timelines, starting with motor and home insurance Art.4 requires further clarity especially whether the customer should have the right to access this data themselves, automate such data access with software, or authorize a FISP to access the data on their…
AFME · filed 1 Nov 2023 · source
The Association for Financial Markets in Europe (AFME) believes that the EUs proposed Financial Data Access (FiDA) framework and Payments Services Regulation (PSR), if designed correctly, have the potential to enhance the way banks operate, encourage innovation, and support a more effective and efficient data ecosystem and payments system.
Insurance Ireland · filed 18 May 2021 · source
Ireland is the 5th biggest market for insurance in the EU and the second biggest for reinsurance. Irish companies serve customers in more than 110 countries worldwide including 24 EU Member States. A key factor of the success of Irish insurers is the creation and integration of the EU single market, regulatory and supervisory consistency and convergence.
AFME · filed 18 May 2021 · source
AFME is scratch for the opportunity to respond to the European Commission’s Roadmap for an EU strategy for retail investors. AFME welcome the European Commission’s planning towards a comprehensive strategy for retail investors, building on the CMU HLEF report of June 2020.
Filed in French · English published by the European Commission
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