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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.

JSE
4
files engaged
of 583 tracked
4
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
IE
Insurance Europe

Industry association · Belgium

37
files engaged
of 583 tracked
47
positions filed
in those 583 files
35
declared FTE
self-declared
19
EP accreditations
as declared to the register

Declared costs: €6M+ a year · in the register since 2010

Files both filed on (2)

Digital Levy · Long Term Investment Funds – Review of EU rules

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.

Digital Levy

JFMO SERVICIOS EN INTERMEDIACIÓN PÚBLICA · filed 18 Jan 2021 · source

Is it fair to pay more taxes in a digital economy? Every economic entity is taxed according to the laws of each country. In some countries, taxes are paid on income, at the value added to the asset Excise duties on production and services, creating an unfair tax burden. In short, too much and abuse.

Filed in Spanish · English published by the European Commission

Insurance Europe · filed 11 Feb 2021 · source

Insurance Europe welcomes the possibility to comment on the roadmap for the introduction of a digital tax to address the issue of fair taxation of the digital economy. Key points - While data is important for insurers and reinsurers, and they use data from different sources, (re)insurance is not a highly digitalised business model.

Long Term Investment Funds – Review of EU rules

JFMO SERVICIOS EN INTERMEDIACIÓN PÚBLICA · filed 17 Sept 2020 · source

It is important to define investment funds in their various forms, such as Fija, variable, variable, absolute returns. In addition to establishing public debt ceilings through loans incurred through investment funds or index funds for greater convenience.

Filed in Spanish · English published by the European Commission

Insurance Europe · filed 14 Oct 2020 · source

The European insurance industry supports the European Commission’s intention to make improvements to the European Long-Term Investment Funds Regulation (ELTIF) framework, as indicated in its Capital Markets Union (CMU) Action Plan (Action 3). The insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, for the benefit of its policyholders.

Insurance Europe · filed 21 Mar 2022 · source

The European insurance industry welcomes the European Commission’s proposal to review the European Long-Term Investment Funds (ELTIF) Regulation. As the insurance industry needs access to a wide range of assets that provide attractive returns and portfolio diversification, improvements made to the ELTIF framework to make it more appealing to institutional investors are supported.

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