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.
Position Paper June 2025 Cybersecurity Act Revision Summary The Cybersecurity Act (CSA) was introduced in 2019 as a central instrument of the European Union to strengthen the cyber security of information and communication technologies. At the time, there were no other European harmonized requirements for products concerning cybersecurity.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The business representatives of the German KRITIS Implementation Partnership (UP KRITIS), a public-private partnership between operators of critical infrastructures and the relevant authorities with more than 1000 member organizations in Germany, want to give feedback to the 4 main topics in the revision of the Cyber Security Act (CSA2) in the attached position paper 1. Expanded ENISA Mandate 2.
Titel Ref. Ares(2026)4818540 - 12/05/2026 Revision of the EU Cybersecurity Act Position of the German digital industry on the European Commission’s proposal for a CSA-2 1 Cybersecurity Act 2 Content 1 Summary 3 2 TITLE II: THE EUROPEAN UNION AGENCY FOR CYBERSECURITY 5 TITLE III: EUROPEAN CYBERSECURITY CERTIFICATION FRAMEWORK 8 3 Article 71: Objectives and scope of the European cybersecurity certification framework 9…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Position Paper 2026 May NIS-2 Amendments Summary The NIS-2 Directive set the goal to establish a unified legal framework to uphold cybersecurity in critical sectors across the EU. By defining technical and methodological requirements for cybersecurity risk management measures, it aims to create a harmonised baseline level of protection.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Bitkom strongly welcomes the integration of relevant stakeholder opinions in order to streamline public and private efforts striving for an improved cybersecurity throughout the European Union (EU). That is why we would like to seize the opportunity and provide our feedback already at an early stage of the revision of the Directive (EU) 2016/1148 concerning measures for implementing an equivalent and commonly high…
The members of UP KRITIS (Public Private Partnership of the German Critical Infrastructure Managers) welcomed the revision of the NIS Directive 2.0. With a view to increasing network and information security in the European internal market in an effective and cost-effective manner, we would like to draw attention to the following possible improvements to the Commission’s legislative proposal of 16.12.2020 and ask it…
Filed in German · English published by the European Commission
As a matter of fact cyber threats have increased manifold since the adoption of the first NIS Directive. That's why we see the imperative need for a more harmonised and future-proofed European cybersecurity framework. The proposal already strikes a reasonable balance between targeted regulatory interventions and strengthening the EU's cyber-resilience holistically.
As the voice of the German digital economy, Bitkom highly appreciates the opportunity to provide feedback on the European Commission’s consultation on the possible review of the existing European Critical Infrastructure Directive. Please take our extensive feedback from the attached file.
UP KRITIS is a private-public partnership of operators of essential services (OES) and public authorities. This statement is the result of the business representatives (OES) in UP KRITIS , who welcome the EU project but give some points to consider. 1.
Bitkom agrees that the existing framework for protecting critical infrastructures is inadequate in the light of increasing interdependencies and evolving risks. The changing nature of the threat landscape requires both better protection and more investment in resilience capacities to secure our critical infrastructure.
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