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.
I. INTRODUCTION On April 11, 2025, the European Commission initiated a public consultation to support the revision of the EU Cybersecurity Act (Regulation (EU) 2019/881). The proposed updates aim to clarify ENISAs role, improve the European Cybersecurity Certification Framework, and ensure that cybersecurity measures are better aligned with the evolving digital ecosystem and legal framework.
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.
The Enel Group, a multinational energy company, welcomes the revision of the Cybersecurity Act (EU) 2019/881 and considers the revision of the Cybersecurity Act (CSA 2.0) as a strategic step towards strengthening the European Unions cyber resilience.
Dear Members of DG CNECT H2, Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to review the Directive (EU) 2016/1148. The first suggestion to revise the future legislation relates to the provisions allowing Member States to define essential services and identify operators of essential services in their territories.
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
Dear Members of European Commission, DG CNECT Unit H.2; Enel SpA, a multinational company in the energy sector highly appreciates the EC prompt revision of the Directive on the security of network and information systems (EU) 2016/1148. Please find the Enel Group feedback in the attachment.
Enel Group welcomes the Commission’s initiative and the intent to intensify the pace of the measures to enhance the protection and resilience of critical infrastructure through the establishment of a more comprehensive legislative framework.
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.
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