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
Industry association · Germany
Declared costs: under €10K a year · in the register since 2009
Framework for Financial Data Access · Payment services in the internal market · Payment services and electronic money services in the Internal Market
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.
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.
International Personal Finance (IPF) · filed 1 Nov 2023 · source
IPF hopes that the FIDA proposal will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector.
German Banking Industry Committee · filed 25 Oct 2023 · source
GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Regulation and contribute to the legislative debate. Please find attached our detailed comments and positions on the proposal. The German Banking Industry Committee (GBIC) is the joint committee operated by the central associations of the German banking industry.
International Personal Finance (IPF) · filed 1 Nov 2023 · source
IPF hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector. For the upcoming legislative procedure, IPF urges lawmakers in the European Parliament and the Council to use the revision of PSD2 as an opportunity to avoid excessive requirements and increased bureaucracy.
German Banking Industry Committee · filed 25 Oct 2023 · source
GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Directive and contribute to the legislative debate. Please find attached our detailed comments and positions on the proposal. The German Banking Industry Committee (GBIC) is the joint committee operated by the central associations of the German banking industry.
International Personal Finance (IPF) · filed 1 Nov 2023 · source
IPF hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector. For the upcoming legislative procedure, IPF urges lawmakers in the European Parliament and the Council to use the revision of PSD2 as an opportunity to avoid excessive requirements and increased bureaucracy.
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