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.
Academic / research · Italy
Industry association · Germany
Declared costs: €1M+ a year · in the register since 2008
Cyber Resilience Act · Type approval of motor vehicles regarding access to in-vehicle generated data
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.
University of Florence and CNIT · filed 21 Mar 2022 · source
Security and privacy in digital products delivered in the EU must be CE certified (as any other product) as secure and respecting data privacy. Also the last point (privacy) must be addressed by means of new disruptive technologies that by default must guarantee user data protection as GDPR alone, being only normative rules, is not sufficient even now and more in the future digital systems (6G, AI, IoT, etc.).
Bitkom e.V. · filed 20 Jan 2023 · source
Bitkom appreciates the opportunity to provide feedback on the Commissions proposal for a Cyber Resilience Act. Please find our position paper attached. We welcome the proposal to create a more efficient legal framework to improve cybersecurity in Europe. Nevertheless, some important aspects should be optimized and clarified during the legislative process.
University of Florence and CNIT · filed 13 May 2022 · source
Security and privacy in the access to vehicle data are critical issues and must be guaranteed. All digital products dealing with vehicle data delivered in the EU must be CE certified (as any other product) as secure and respecting data privacy.
Bitkom e.V. · filed 2 Aug 2022 · source
Bitkom welcomes the EU Commission's initiative with the aim to facilitate the use of data for a smarter, safer, and sustainable mobility ecosystem. However, we would like to also underline that relying on market principles will be key to fostering the enormous potential of data-driven solutions in the field of mobility.
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