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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.

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)

Transparency and integrity of Environmental, Social and Governance (ESG) rating activities · Increasing the attractiveness of public capital markets and facilitating access to capital for SMEs – amending Directive

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.

Transparency and integrity of Environmental, Social and Governance (ESG) rating activities

Norges Bank Investment Management · filed 10 Aug 2023 · source

Norges Bank Investment Management is the investment management division of the Norwegian Central Bank (Norges Bank) and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with 12,429 billion Norwegian kroner, or around 1,186 billion EUR, at year end 2022.

BETTER FINANCE · filed 1 Sept 2023 · source

BETTER FINANCE position and recommendations The draft Regulation urgently needs to: expand protection provisions for retail investors against greenwashing; establish a minimum sustainability requirement for ESG ratings to ensure certain degree of harmonisation between providers going beyond transparency of methodology; include a requirement which can address conflicts of interest by integrating clearly labelled…

Increasing the attractiveness of public capital markets and facilitating access to capital for SMEs – amending Directive

Norges Bank Investment Management · filed 28 Mar 2023 · source

We are referring to the European Commissions proposal for a Directive on multiple-vote share structures in companies that seek admission to trading on an SME growth market, published in December 2022, and the related feedback period. We appreciate the opportunity to contribute our views on this legislative proposal.

BETTER FINANCE · filed 28 Mar 2023 · source

BETTER FINANCE welcomes the stated objectives of the listing act review for prospectus standardisation and streamlined IPO cost reduction, particularly for SMEs. Investor protection both relies on reporting that must be adequate, accessible and on fair treatment.

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