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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.

PLA
PlayRight

Company · Belgium

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
VNM
VNO-NCW & MKB-Nederland

Industry association · Netherlands

11
files engaged
of 583 tracked
11
positions filed
in those 583 files
5.8
declared FTE
self-declared
3
EP accreditations
as declared to the register

Declared costs: €1M+ a year · in the register since 2010

Files both filed on (2)

Targeted initiative for a better copyright environment for European creativity and innovation · Proposal on the conditions for the remuneration of third country recorded music played in the EU

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.

Targeted initiative for a better copyright environment for European creativity and innovation

PlayRight · filed 25 Jun 2026 · source

PlayRights experience shows that the CDSM Directive has not delivered the meaningful improvements for performers that were originally envisaged. Although it introduced important principles, such as appropriate and proportionate remuneration and greater transparency, these objectives have largely remained unrealized in practice.

VNO-NCW & MKB-Nederland · filed 25 Jun 2026 · source

VNO-NCW and MKB-Nederland, representing businesses across all sectors of the Dutch economy, strongly welcome the fact that the European Commission is now explicitly considering legislative action in response to the consequences of the RAAP judgment (Case C-265/19).

Proposal on the conditions for the remuneration of third country recorded music played in the EU

PlayRight · filed 21 Sept 2022 · source

PlayRight* strongly supports the initiative defined in the present Call for Evidence and appeals to the Commission to pursue the said initiative with the highest priority. You will find our feedback in attachment. *PlayRight is the collective management organisation (CMO) of neighbouring rights for performing artists in Belgium and manages as such the single equitable remuneration.

VNO-NCW & MKB-Nederland · filed 22 Sept 2022 · source

Input Call for evidence – DG Connect I.2 Copyright September 22, 2022 The Commission is considering an initiative that would introduce rules for third country nationals, whether natural or legal persons, by amending the article 8 (2) of the Directive 2006/115/EC on rental and lending rights (RLR directive). We fully support this initiative and hope for rapid implementation.

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