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.
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.
Finance Denmark has submitted a joint response to the Commission’s consultation together with the Swedish Bankers’ Association and Finance Finland. In the proposal, the Commission has chosen an approach for the output floor that applies the floor also on capital requirements beyond the capital requirements agreed upon at international level.
For the attention of DG FISMA Dear Madam, dear Sir, Thank you for requesting feedback on the draft CRR dated 27th October 2021. We are pleased in the name of ITFA to submit the attached paper for your consideration. Kind regards, For and on behalf of ITFA International Trade and Forfaiting Association
Finance Denmark welcomes the initiative to revise the 2014 eIDAS Regulation, extending it to the private sector and promoting trusted identities, in general, across Europe. In Denmark, we have had a well-functioning public/private digital ID solution since 2010 called NemID. It is a public private partnership collaboration between the Danish banks and the public sector.
The International Trade and Forfaiting Association (ITFA) is grateful for the opportunity to express the initial views related to the planned eIDAS review. We believe that the eIDAS review presents an excellent opportunity to consider various aspects that can help boost international trade.
Extract of the full document in Annex: We welcome the intention to develop an EU digital ID scheme with an ambition to ensure a much greater use of digital authentication across the member states. Particularly, we note that this is supported by broadening the scope of the eIDAS regulation to also cover services offered by private companies.
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