Side by side
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.
Company · United Kingdom
Company · Spain
Declared costs: €2M+ a year · in the register since 2008
Digital Markets Act · Guidelines on exclusionary abuses of dominance
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
Oxera Consulting LLP · filed 30 Jun 2020 · source
Oxera is pleased to provide feedback on the Commission’s initiative for an Ex Ante regulatory framework for online platforms. In the interests of transparency, we would like to state that we are currently advising several technology firms and an industry body on issues around the Digital Services Act. The feedback and opinions provided here are entirely our own.
Telefonica, S.A. · filed 29 Apr 2021 · source
TELEFONICA’S POSITION ON THE COMMISSION’S DIGITAL MARKETS ACT (DMA) PROPOSAL EXECUTIVE SUMMARY Telefónica endorses the objective to promote fair and contestable markets by regulating the activities of platform service providers with significant impact on the Internal Market. We believe that there are a number of ways the effectiveness of the proposal could be improved.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Oxera Consulting LLP · filed 24 Apr 2023 · source
Oxera welcomes the call for evidence and comments by the European Commission (Commission) regarding future guidelines for the application of Article 102 TFEU, and the insights provided in the Briefing Paper that accompanies the Communication on the amendments of the 2008 Guidance Paper.
Telefonica, S.A. · filed 24 Apr 2023 · source
Telefónica welcomes the Commissions call for evidence ahead of the adoption of the Guidelines on exclusionary abuses of dominance. Please find Telefónica's response to the call for evidence on the attached file. Our response is mainly related to the Commissions amendments to the Guidance on the enforcement priorities in applying Article 82 of the Treaty to abusive exclusionary conduct by dominant undertakings.
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