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: €800K+ a year · in the register since 2009
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.
EuroCommerce · filed 10 Dec 2020 · source
The following comments on the Commission roadmap on standard contractual clauses (SCCs) for the transfer of data to third countries pursuant to Regulation (EU) 2016/679 (Implementing Decision) are being submitted jointly by EuroCommerce, headquartered in Brussels, and the National Retail Federation (NRF), headquartered in the United States, which will be submitting the identical set of comments in parallel to this…
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.
EuroCommerce · filed 11 Feb 2021 · source
To make the tax system suitable for the digitalised economy, EuroCommerce calls for the modernisation of existing international tax rules, consistent with the following principles: Fair - A modern taxation system should be channel-neutral and operate equitably across industries and between different forms of business activities and business models.
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