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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.

UK
UP KRITIS

NGO · Germany

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
DIG
DIGITALEUROPE

Industry association · Belgium

67
files engaged
of 583 tracked
78
positions filed
in those 583 files
26.7
declared FTE
self-declared
26
EP accreditations
as declared to the register

Declared costs: €3.5M+ a year · in the register since 2011

Files both filed on (3)

Amending the NIS 2 Directive as regards simplification measures and alignment with the Cybersecurity Act 2 · A high common level of cybersecurity · Resilience of critical entities

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.

Amending the NIS 2 Directive as regards simplification measures and alignment with the Cybersecurity Act 2

DIGITALEUROPE · filed 20 Jun 2025 · 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.

UP KRITIS · filed 1 Apr 2026 · source

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.

DIGITALEUROPE · filed 11 May 2026 · source

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.

A high common level of cybersecurity

DIGITALEUROPE · filed 13 Aug 2020 · source

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.

UP KRITIS · filed 18 Mar 2021 · source

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

DIGITALEUROPE · filed 18 Mar 2021 · source

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.

Resilience of critical entities

DIGITALEUROPE · filed 6 Aug 2020 · source

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 · filed 31 Mar 2021 · source

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.

DIGITALEUROPE · filed 8 Apr 2021 · source

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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