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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.

KL
Konfederacja Lewiatan

Industry association · Poland

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register

Files both filed on (2)

Revision of the Union Customs Code · Simplification of the Union framework on direct taxation

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.

Revision of the Union Customs Code

Finnwatch ry · filed 14 Sept 2022 · source

Finnwatch welcomes the planned reform of the UCC and this opportunity to provide feedback. As an NGO that investigates human rights abuses in global supply chains and facilities redress and remedies for victims, we need access to supply chain information. Whereas some pioneering companies are forthcoming with this information, many companies are not.

Finnwatch ry · filed 13 Sept 2023 · source

Finnwatch would like to thank the Commission for the opportunity to provide feedback on the Commission proposal for a regulation establishing the Union Customs Code and the European Union Customs Authority (and repealing the existing UCC).

Konfederacja Lewiatan · filed 20 Sept 2023 · source

In connection with the work of the European Commission on the reforms of the EU Customs Code, we would like to provide an opinion. We also Attach a report from a survey conducted among our members on the impact of the above reforms on the activities of entrepreneurs. The position papers is attached below.

Filed in Polish · English published by the European Commission

Simplification of the Union framework on direct taxation

Konfederacja Lewiatan · filed 18 Mar 2026 · source

Responding to the invitation to add any comments or suggestions on possible solutions to simplify European Union law and improving the functioning of the EU legal framework for corporate taxation, we wish to submit our proposals. Please find the attached.

Filed in Polish · English published by the European Commission

Finnwatch ry · filed 30 Mar 2026 · source

The EU Commission's calls for simplification of the tax system are reasonable, given the administrative burden of navigating 27 distinct national tax systems. However, it is important to consider carefully revisions to directives such as ATAD in order not to undermine their policy objectives. Many proposals framed as simplifications risk creating more space for profit shifting and aggressive tax planning.

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