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.
Dear Commission, Please find attached our feedback on the draft Data protection - standard contractual clauses for transferring personal data to non-EU countries (implementing act). Best regards, [name removed] and [name removed] on behalf of the Norwegian Institute of Public Health (NIPH)
BSA | The Software Alliance (“BSA”), the leading advocate for the global software industry, welcomes the opportunity to provide feedback on the European Commission’s draft new standard contractual clauses (“SCCs”) for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679. We respectfully submit the comments attached in response to the Commission’s consultation on the New SCCs.
Dear Commission, Please find attached our feedback on the draft Data protection - standard contractual clauses for transferring personal data to non-EU countries (implementing act). Best regards, [name removed] and [name removed] on behalf of the Norwegian Institute of Public Health (NIPH)
BSA | The Software Alliance (“BSA”), the leading advocate for the global software industry, welcomes the opportunity to provide feedback on the European Commission’s draft new standard contractual clauses (“Article 28 SCCs”) on the matters referred to in Article 28(3) and (4) of Regulation (EU) 2016/679.
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