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 · Netherlands
Declared costs: €100K+ a year · in the register since 2014
Industry association · Belgium
Declared costs: €200K+ a year · in the register since 2010
Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries · Digital Levy
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.
Prosus · filed 10 Dec 2020 · source
Prosus is thankful for the opportunity to provide feedback on the revision of the standard contractual clauses for the transfer of personal data to third countries. In summary, we would like to raise the following points. For more details, please see our attached comments. 1.
ACT | The App Association · filed 10 Dec 2020 · source
Dear Sir or Madam, Please find attached ACT | The App Association's comments to Standard contractual clauses – Commission implementing decision on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. Sincerely, [name removed] ACT | The App Association
ACT | The App Association · filed 3 Feb 2021 · source
Please find attached comments of ACT | The App Association (Transparency Reg. # 7202951387754) on the European Commission’s Roadmap "‘Digital Levy Legislative Proposal". Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 7202951387754) Rue de Trèves 45 B-1040 Brussels
Prosus · filed 9 Feb 2021 · source
Prosus, an EU-headquartered, global consumer internet group and one of the largest technology investors in the world (www.prosus.com), welcomes the possibility to contribute to the design of a modern, stable regulatory and tax framework for the digital economy in the EU. We strongly support the aim to reach a global, profit-based solution to the challenges arising from the digitalisation of the economy.
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