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.
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.
Representing more than 25,000 oncology professionals from over 160 countries, the European Society for Medical Oncology (ESMO) welcomes the proposal for the European Health Data Space (EHDS) and its intention to improve patient access to their health data and facilitate the use of health data for research and innovation.
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.
The European Society for Medical Oncology (ESMO), representing over 50,000 members globally, welcomes the publication of the draft Implementing Act laying down the minimum metadata elements and their characteristics to be provided by health data holders for dataset descriptions for the secondary use of electronic health data under the European Health Data Space (EHDS) Regulation.
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