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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.

SFB
Swedish Federation of Business Owners

Industry association · Sweden

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
EUR
EuroCommerce

Industry association · Belgium

53
files engaged
of 583 tracked
58
positions filed
in those 583 files
8.3
declared FTE
self-declared
18
EP accreditations
as declared to the register

Declared costs: €800K+ a year · in the register since 2009

Files both filed on (2)

Commercial transactions: combating late payment · VAT in the Digital Age

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.

Commercial transactions: combating late payment

Swedish Federation of Business Owners · filed 15 Mar 2023 · source

The Swedish Federation of Business Owners (Swedish Federation of Business Owners) is co-founder of the Association for Effective Business Transactions (www.betaltider.se). In dialogue with the Swedish Government and a number of representatives from large companies, we have worked on various proposals and solutions to shorten payment times in Sweden.

Filed in Swedish · English published by the European Commission

EuroCommerce · filed 17 Mar 2023 · source

EuroCommerce stands by a culture of prompt payments in government-to-business and business-to-business transactions. A key differentiation must be drawn between late payments (which occur beyond the terms agreed by the parties) and business-to-business contractually agreed longer payment terms, which form part of the economic decision of the parties and reflect the financing needs of both sellers and buyers.

EuroCommerce · filed 9 Nov 2023 · source

EuroCommerce stands by a culture of prompt payment. Late payments (which negatively affect creditors liquidity management) should not be confused with negotiations of payment terms agreed upon between contracting parties. Removing the possibility to negotiate payment terms restricts freedom of contract and will have numerous adverse effects that are not considered in the Impact Assessment of the European Commission.

VAT in the Digital Age

EuroCommerce · filed 29 Mar 2023 · source

EuroCommerce, representing the European retail and wholesale sector, are pleased to provide detail comments on the proposal on VAT in the digital age in the attached document. EuroCommerce welcomes the opportunity to provide feedback on the VAT in the Digital Age proposal of the European Commission.

Swedish Federation of Business Owners · filed 4 Apr 2023 · source

The Federation of Swedish Business Owners (Företagarna) wishes to give the following feedback regarding the proposed Council regulation. We acknowledge the need for further harmonised rules regarding VAT in cross-border trade in the single market. The most central aspects of the sharing of information between member states' authorities are necessary to facilitiate simplified VAT handling.

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