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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.

II
Insurance Ireland

Industry association · Ireland

4
files engaged
of 583 tracked
6
positions filed
in those 583 files
2.7
declared FTE
self-declared
4
EP accreditations
as declared to the register

Declared costs: €400K+ a year · in the register since 2017

GBI
German Banking Industry Committee

Industry association · Germany

37
files engaged
of 583 tracked
45
positions filed
in those 583 files
13
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: under €10K a year · in the register since 2009

Files both filed on (3)

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.

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.

Retail investor protection rules

German Banking Industry Committee · filed 27 May 2022 · source

We appreciate to have the opportunity to share our comments how to increase consumer participation in capital markets. GBIC is convinced that consumer participation can only be enhanced when clients are able to choose between commission-based and fee-based advice. Therefore, the GBIC is strictly against a ban of 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.

German Banking Industry Committee · filed 28 Aug 2023 · source

On 24 May 2023, the European Commission published a draft for the amendment of the PRIIPs Regulation (PRIIPs Draft) within the framework of its Retail Investment Strategy (RIS). The German Banking Industry Committee (GBIC) welcomes the intention of the European Commission to also revise the PRIIPs Regulation within the framework of the RIS.

German Banking Industry Committee · filed 28 Aug 2023 · source

The German Banking Industry Committee (GBIC) supports the European Commissions intention to use the retail investment strategy (RIS), developed as part of the capital markets union, to make the securities business more consumer-friendly and thereby encourage retail investors to invest in EU capital markets.

Framework for Financial Data Access

German Banking Industry Committee · filed 2 Aug 2022 · source

The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. The following comments supplement our response to the Commission’s targeted consultation on 5 July 2022.

German Banking Industry Committee · filed 26 Oct 2023 · source

With the draft Framework for Financial Data Access (FIDA), the EU Commission aims to facilitate access to customer data for a wide range of financial services. This is intended to promote the exchange of data between companies in the financial sector as a whole. Thus, FIDA sets the regulatory framework for open finance.

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…

Retail Investment Strategy

German Banking Industry Committee · filed 12 May 2021 · source

GBIC welcomes the opportunity to comment on the Commission’s roadmap: 1. Inducements A potential ban on inducements would run counter the roadmap’s explicit aim to raise the level of participation by retail investors in financial markets.

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.

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