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: €2.8M+ a year · in the register since 2008
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 Insurance Association (GDV) · filed 28 Nov 2023 · source
The German Insurance Association welcomes the European Commissions initiative to reduce the burden of reporting and fully supports the call for evidence on the rationalisation of reporting requirements. Please find our detailed proposals in the attached position paper.
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…
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 Insurance Association (GDV) · filed 31 Oct 2023 · source
The German insurance industry generally supports the European considerations to promote a data-driven financial system. With the presented legislative proposal on a framework for access to financial data ("FiDA"), retail and corporate customers are to be given more creative scope in the use of their financial data.
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