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.
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.
EFPIA welcomes the proposal to create sectoral and horizontal legislative frameworks to unlock the value of data, support the use, re-use and exchange of health data at the EU level and ensure coherence between the operation of the different legislations contributing to the functioning of the Data Space.
RWE4Decisions welcomes the Commission’s EHDS proposal: it is an ambitious step forward that can contribute to a sustainable real-world data (RWD) ecosystem by addressing the current fragmentation and lack of health data infrastructure within and across Member States, making sure the data are interoperable and of high-quality.
The legislative proposal on a European Health Data Space (EHDS) and respective horizontal proposals provide an unprecedented opportunity to shape the future health data and digital ecosystem. Digital transformation has the potential to increase the innovation and productivity of the EU economy and ensure that Europe remains an innovator and world leader in the development and manufacture of medicines, supporting…
The RWE4Decisions initiative welcomes this draft Implementing Regulation. As a multi-stakeholder initiative dedicated to improving the generation and use of realworld evidence (RWE) to inform HTA and payer decisionmaking, we strongly support the objective of enhancing transparency, discoverability, interoperability and trust in electronic health data for secondary use across the EU.
EFPIA welcomes the opportunity to comment on the draft Commission Implementing Act laying down the minimum metadata elements and their characteristics for dataset descriptions under the European Health Data Space (EHDS).
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