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.
The EUs cybersecurity framework has undergone substantial expansion since the adoption of the Cybersecurity Act (CSA) in 2019. Alongside the CSA, new legislative instruments including NIS2, the Cyber Resilience Act (CRA), DORA and the Cyber Solidarity Act now define a much more comprehensive and multi-layered regulatory architecture for cybersecurity across the single market.
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.
See attached the full position. Summary: In the recent years, the EU has built one of the worlds most ambitious regulatory frameworks for cybersecurity, driven by rising cybersecurity risks. The challenge the newly proposed cybersecurity package must meet is to make it work in practice.
As the voice of digitally transforming industries in Europe, DIGITALEUROPE appreciates the opportunity to provide feedback on the European Commission’s roadmap consultation on the review of EU rules on the security of network and information systems.
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
The review of the Directive on Security of Network and Information Systems (NIS2) is an essential step towards a more resilient Europe, ensuring state-of-the-art risk management of current and emerging cyber threats to vital sectors of the EU economy and society.
DIGITALEUROPE welcomes the opportunity to provide a response to the Commission’s consultation on the possible review of the existing Critical Infrastructure Directive (hereinafter “ECI Directive”) and the subsequent inception impact assessment.
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.
The changing nature of the threat landscape requires better protection and more investment in the EU’s resilience capacities to secure our critical infrastructure. DIGITALEUROPE welcomes the Commission’s effort to strengthen the resilience of critical entities across the EU by developing and updating relevant legislation.
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