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.
Industry association · Belgium
Declared costs: €50K+ a year · in the register since 2013
Industry association · Germany
Declared costs: under €10K a year · in the register since 2009
Rationalisation of reporting requirements · Framework for Financial Data Access
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.
German Banking Industry Committee · filed 28 Nov 2023 · source
Preliminary remarks The German Banking Industry Committee (GBIC) welcomes the European Commissions goal of a 25 percent reduction in the burden on companies and administrative organizations resulting from reporting requirements.
PensioPlus · filed 1 Dec 2023 · source
PensioPlus welcomes the European Commissions initiative to ease burdensome reporting requirements. Administrative burden is identified by Belgian IORPs as greatest threat to their survival. In the past years, the regulatory burden on IORPs has increased significantly due to the 2016 review of the IORP Directive, the introduction of additional EIOPA reporting requirements and applicable horizontal legislation such as…
German Banking Industry Committee · filed 2 Aug 2022 · source
The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. The following comments supplement our response to the Commission’s targeted consultation on 5 July 2022.
PensioPlus · filed 24 Oct 2023 · source
Occupational pension funds (IORPs) are included in the scope of this proposal. PensioPlus stresses that second pillar pension funds are inherently different from other financial market entities. IORPs are not-for-profit, they operate in a triangular relationship with social partners and do not have any shareholders and, most importantly, they do not sell any products, since employees mainly benefit from mandatory…
German Banking Industry Committee · filed 26 Oct 2023 · source
With the draft Framework for Financial Data Access (FIDA), the EU Commission aims to facilitate access to customer data for a wide range of financial services. This is intended to promote the exchange of data between companies in the financial sector as a whole. Thus, FIDA sets the regulatory framework for open finance.
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