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
Other · Germany
Declared costs: €10K+ a year · in the register since 2021
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.).
GISAD i.G. · filed 25 May 2022 · source
>>Challenges: GISAD welcomes the EU Commission's intention for a cyber resilience law. However, it is doubted that even option 5 will achieve the desired purpose. Politicians always want to regulate something after the fact, when a wrong development has been identified.
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.
GISAD i.G. · filed 17 Jun 2022 · source
Challenges: GISAD welcomes the EU Commission's initiative to regulate access to vehicle data. Appropriate is option 3, to impose legal requirements in addition to prescribing a list of the data. The customer can remain largely anonymous if the state of the art is exhausted. For example, 1,000 IP addresses can be made available per user, which are used randomly, as described in patent application DE102017005550 (A1).
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